Fatima Begum And 3 Others vs The State Of Telangana And 3 Others on 29 July, 2026

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    Telangana High Court

    Fatima Begum And 3 Others vs The State Of Telangana And 3 Others on 29 July, 2026

     HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
           HON'BLE SRI JUSTICE LAXMI NARAYANA ALISHETTY
    
                          WRIT PETITION No.1033 of 2020
    
                             DATE OF ORDER:29.07.2026
    
    
    BETWEEN:
    Fatima Begum and three others
                                                                    ....... Petitioners
    And
    The State of Telangana, reptd by its
    Principal Secretary, Revenue Department,
    Hyderabad and three Others
                                                                     ....Respondents
    
    
    ORDER:

    This Writ Petition is filed to issue a writ of Mandamus declaring the orders

    passed by respondent No.3 in Case No.C/2307/2019, dated 23.12.2019 directing

    SPONSORED

    respondent No.4 to delete the names of the petitioners in respect of land

    admeasuring Acs.9.37 guntas in Sy.No.18 of Rangapur Village and to take over

    the possession of the land into custody of the Government by recording the land

    as ‘Government Kharij Khata’ as illegal, arbitrary and against principles of

    natural justice and in violation of Articles 14, 16, 21 and 300-A of Constitution

    of India and the orders passed by this Court in W.P.No.27640 of 2019 dated

    13.12.2019 and consequently, to set aside the order dated 23.12.2019.
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    LNA, J
    WP.No.1033 of 2020

    2. Heard Sri M.A.Mujeeb, learned counsel for petitioners, and learned

    Assistant Government Pleader for Revenue for Respondents.

    3. The brief facts as averred in the writ petition are that the petitioners are

    the owners and possessors of land admeasuring Acs.10.01 guntas situated at

    Rangapur Village Basireddypalli Grampanchayath Pargi Mandal, Ranga Reddy

    District in Sy.Nos.18/A2/1, 18/A/2/2, 18/A/3/1, 18/A/3/2, 18/A/1, 18/A/2,

    18EE/1/1, 18/EE/2/1, 18/EE/3/1, 18/EE/3/2, 18/E/2, 18/E/1, 18/EE/1/2,

    18/EE/2/2, 18/EE/1/2 and 18/A/1/1 (herein-after referred to as subject property),

    having purchased the same under a registered Sale Deed No.1879 of 2014 dated

    18.09.2014.

    3.1. It is further stated that while so, suo motu appeal was taken on file by the

    office of Respondent No.3 under Section 5(5) of the Telangana Rights in Land

    and Pattadar Passbooks Act,1971 (for brevity, ‘the Act 1971’) pursuant to the

    directions issued by the District Collector; that the petitioners, on receiving

    notice of the suo-moto enquiry, had repeatedly requested for furnishing copies

    of the documents forming basis of the suo motu enquiry, but respondent No.3

    failed to furnish the relevant records, thereby depriving the petitioners of an

    effective opportunity to submit their reply thereto; that the petitioners had

    earlier approached this Court by filing W.P.No.27640 of 2019, wherein this

    Court specifically directed the Revenue Divisional Officer to furnish the

    relevant documents to the petitioners upon their request, consider the objections
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    WP.No.1033 of 2020

    of the petitioners and thereafter proceed in accordance with law; that, contrary

    to the directions of this Court, the Revenue Divisional Officer, instead of

    furnishing all the relevant documents, has furnished only a Memo dated

    19.11.2019, Proceedings No.B/7193 of 2007 and B/7352 of 2007 dated

    25.02.2008 of the Tahsildar, Pargi, while withholding the remaining documents

    which were relied upon in the enquiry, and further, that without giving an

    opportunity to file proper reply, respondent No.3 proceeded to pass the

    impugned order on 23.12.2019. Aggrieved by which, the petitioners filed

    contempt case vide CC(SR).No.1289 of 2019.

    4. Learned Counsel further submitted that the suo motu proceedings were

    initiated based on a representation submitted by one Venkataiah, District

    General Secretary, Telangana Agriculture Workers Union, Vikarabad District

    Committee, before respondent No.2, to which the petitioners were not made

    parties; that the petitioners were never associated with any enquiry nor were put

    on notice preceding the initiation of the suo motu appeal.

    4.1. He further submitted that the impugned order suffers from arbitrariness

    inasmuch as another purchaser, namely Sri Vijay Kumar, whose name was

    mutated by the same revenue authorities, was not proceeded against, whereas

    the names of the petitioners alone were directed to be deleted from the revenue

    records, without any rational basis; that the petitioners had purchased the

    property only after obtaining clarification from the Tahsildar regarding the
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    WP.No.1033 of 2020

    status of the land and had acted bona fide. The direction to classify the subject

    land as Government Kharij Khata and to take over possession of the same is

    therefore illegal and threatens the petitioners with imminent dispossession.

    5. By contending as above, learned Counsel for petitioners finally submitted

    that the impugned proceedings are arbitrary, illegal, violative of the principles of

    natural justice and contrary to the directions issued by this Court in W.P.

    No.27640 of 2019, and hence, are liable to be set aside.

    6. In support of his contentions, learned counsel for petitioners relied on the

    judgments in WP No.15955 of 2019 (Syed Jaffar Ahmad v. District Collector)

    and WP.No.12372 of 2019 (SPPS Systems Private Limited v. State of

    Telangana).

    7. Learned Assistant Government Pleader for Revenue, appearing for the

    respondents, submitted that the impugned proceedings was passed strictly in

    accordance with law and after following the procedure contemplated under the

    Act, 1971. He submitted that the suo motu appeal was initiated by the Revenue

    Divisional Officer pursuant to the Memo No.A1/3381/2019 dated 19.11.2019

    issued by respondent No.2, directing an enquiry into the legality of the

    mutations effected in respect of the subject land.

    7.1. She further submitted that as per the basic revenue records, i.e., Sessala

    Pahani (1955-58), the land in Sy.No.18 admeasuring Acs.14.39 guntas was
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    WP.No.1033 of 2020

    classified as “Sarkari Kharij Khata” and subsequently, portions of the land

    were shown as “Kharij Khata Patta (Laoni Patta)” in the names of certain

    individuals and then as patta lands, this change in classification of land from

    “Kharij Khata Patta” to “Patta” in the revenue records had no legal basis; that

    the petitioners’ predecessors had no valid title to convey; that the petitioners had

    purchased assigned (Laoni) lands without obtaining the requisite permission or

    No Objection Certificate from the competent authority; that lands assigned

    under the Laoni Rules are only heritable, but not alienable, and therefore the

    sale transactions relied upon by the petitioners are in violation of the Telangana

    Assigned Lands (Prohibition of Transfers) Act, 1977 and as such, the mutations

    effected in favour of the petitioners were contrary to law.

    7.2. She further submitted that the petitioners were issued notice in the suo

    motu appeal and they had, in fact, challenged the notice before this Court in

    W.P.No.27640 of 2019. Pursuant to the directions issued therein, the petitioners

    appeared before respondent No.3 through their counsel on 21.12.2019. The

    documents available on record were furnished to petitioners and they neither

    sought any additional documents nor produced any material to establish the

    legality of the change in classification of the land or the title of their

    predecessors.

    7.3. Learned Assistant Government Pleader further submitted that upon

    consideration of the available revenue records and the material placed before
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    WP.No.1033 of 2020

    him, respondent No.3 found that the petitioners had failed to establish how the

    land which was originally classified as ‘Government Kharij Khata’ was changed

    to ‘Patta’ or to produce the relevant link documents tracing their title and as

    such, he rightly passed the impugned order.

    7.4. She further submitted that the proceedings were initiated on the basis of

    a complaint received from the District General Secretary of the Telangana

    Agricultural Workers Union alleging irregularities in the mutations made by

    respondent No.4, and that respondent No.2 directed respondent No.3 to enquire

    into the matter. The impugned order was thus passed after considering the

    material available on record and therefore, the same cannot be said to be

    arbitrary.

    7.5. Learned Assistant Government Pleader further submitted that the

    contention of the petitioners that they had purchased the property after obtaining

    clarification from the Tahsildar is unsupported by any documentary evidence

    and has therefore the same was rightly rejected by respondent No.3 in the

    impugned order.

    8. She finally, submitted that against the impugned order, the petitioners

    have an efficacious statutory remedy of appeal before the Joint Collector, but,

    instead of availing the same, the petitioners have directly invoked the writ

    jurisdiction of this Court and on the said ground also, the Writ Petition is liable

    to be dismissed.

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    WP.No.1033 of 2020

    9. This Court has carefully considered the rival submissions advanced by

    the learned counsel appearing for the parties and perused the material available

    on record.

    10. The material placed before this Court discloses that the impugned

    proceedings were initiated pursuant to a representation submitted by the District

    General Secretary of the Telangana Agricultural Workers Union before

    respondent No.2 alleging illegal mutations in respect of the subject land. The

    impugned order proceeds on the premise that the subject land was originally

    classified as “Sarkari Kharij Khata” in the Sethwar and Sessala Pahani (1955-

    58); that it was subsequently shown as “Kharij Khata Patta (Laoni Patta)”; and

    thereafter came to be reflected as “Patta land” in the revenue records without

    any legal basis. Proceeding on such reasoning, respondent No.3 concluded that

    the mutations effected in favour of the petitioners and their predecessors were

    illegal and consequently, directed to record the subject land as ‘Government

    Kharij Khata’.

    11. In Syed Jaffar Ahmad‘s case (cited supra), this Court, while referring to

    the Handbook of Land Records authored by Sri P.Kasthuri Reddy, explained

    that “Kharij Khata” merely denotes portions of patta land are deleted from the

    pattadar’s khata for reasons such as relinquishment of land or on account of

    erosion of land adjoining a river or the land has become useless for cultivation

    or non-payment of land revenue. More importantly, this Court held that once the
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    WP.No.1033 of 2020

    Government itself had subsequently recognised such Kharij Khata land as patta

    land and permitted registrations and effected mutations in the revenue records, it

    cannot, after a considerable lapse of time, seek to ignore the subsequent entries

    and once again claim and treat the land as ‘Government land’ by merely

    referring to its original classification as ‘Kharij Khata’.

    12. The aforesaid principle was further reiterated by this Court in SPPS

    Systems Private Limited‘s case (cited supra), wherein it was held that the

    burden of explaining how the entry in the revenue records changed from Kharij

    Khata to patta land cannot be placed upon the purchaser or landholder. The

    Court observed that the Government and the revenue authorities, being the

    custodians and authors of the revenue records, are required to explain the basis

    for such change. Consequently, mere inability of a purchaser to explain the

    historical alteration in the revenue entries cannot constitute a valid ground to

    invalidate the existing entries or deprive such purchaser of his rights.

    13. In the instant case, the principal reason assigned in the impugned

    proceedings is that the petitioners failed to establish how the entries in the

    revenue records, which originally show the subject land as Kharij Khata, was

    altered as patta land. Such reasoning, in the considered opinion of this Court,

    cannot be sustained in view of the law laid down in the aforesaid judgments.

    Once the revenue authorities themselves have recognised the subject land as

    patta land, effected mutations from time to time and permitted transactions on
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    WP.No.1033 of 2020

    the strength of such entries, the burden cannot thereafter be shifted upon the

    petitioners to explain the historical basis for the alteration of the revenue

    records. It is for the respondents, who are the custodians and authors of the

    revenue records, to explain the basis for such change and further, establish that

    the subsequent entries were illegal or fraudulent and are duty bound to disclose

    the material on the basis of which they seek to disregard the existing revenue

    records. Except relying upon the original entry in the Sethwar and Sessala

    Pahani showing the subject land as Government Kharij Khata, the respondents

    have not placed any material to demonstrate that the subsequent classification of

    the land as ‘patta land’ was without authority of law or that the mutations

    effected over the years were the result of fraud or misrepresentation. In the

    absence of such material, by the impugned order respondent No.3 erred in

    directing deletion of names of the petitioners from the revenue records and

    restoration of the land as ‘Government Kharij Khata’ solely on the ground that

    the petitioners failed to explain the change in classification.

    14. The proposition laid down in the aforesaid judgments squarely applies to

    the facts of the present case. It is pertinent to note that in the instant case, the

    respondents, being custodians and authors of the revenue records, failed to

    discharge the burden cast on them to establish as to how the nature of subject

    lands was changed from ‘Kharij Khata’ to ‘patta land’, by placing any material

    to substantiate the same. Conversely, respondent No.3 in the impugned order
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    WP.No.1033 of 2020

    erred in holding that the petitioners have failed to establish such change of

    classification of subject land, which is unsustainable.

    15. Having regard to the facts and circumstances of the case, and for the

    foregoing reasons and in the light of the law laid down by this Court in Syed

    Jaffar Ahmad‘s case (cited supra) and SPPS Systems Private Limited‘s case

    (cited supra), this Court is of the considered opinion that the impugned

    proceedings of respondent No.3 is unsustainable in law and hence, are liable to

    be set aside.

    16. Accordingly, this Writ Petition is allowed and the impugned proceeding

    No.C/2307/2019 passed by respondent No.3, dated 23.12.2019 is hereby set

    aside.

    17. Miscellaneous petitions pending, if any, shall stand closed. No costs.

    ___________________________________
    LAXMI NARAYANA ALISHETTY, J

    Date:29.07.2026
    Dr



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