Rajasthan High Court – Jodhpur
Girdhari Ram vs The State Of Rajasthan on 13 April, 2026
Author: Pushpendra Singh Bhati
Bench: Pushpendra Singh Bhati
[2026:RJ-JD:14200-DB]
HIGH COURT OF JUDICATURE FOR RAJASTHAN AT
JODHPUR
D.B. Civil Writ Petition No. 23412/2025
Ram Swaroop Kaswa S/o Hari Ram, Aged About 58 Years, R/o
Village Harsolav, Tehsil Gotan, District Nagaur (Raj.).
----Petitioner
Versus
1. State Of Rajasthan, Through Secretary, Department Of
The Panchyat Raj, Government Of Rajasthan, Jaipur.
2. District Collector, Nagaur.
3. Vikas Adhikari, Panchyat Samiti Merta, District Nagaur.
----Respondents
Connected With
D.B. Civil Writ Petition No. 23361/2025
Mahendra S/o Amar, Aged About 27 Years, R/o Sata, Barmer,
Rajasthan 344706
----Petitioner
Versus
1. The State Of Rajasthan, Through Secretary, Department
Of Panchayati Raj, Govt. Of Rajasthan, Secretariat, Jaipur
(Raj.).
2. Divisional Commissioner, Barmer (Raj.).
3. The District Collector, Barmer, Rajasthan.
4. The Sub-Divisional Officer, Sedwa, Barmer, Rajasthan.
5. Gram Panchayat, Sata, Through Its Sarpanch, Office Of
Gram Panchayat Samiti Sata, Tehsil Sedwa, District
Barmer, Rajasthan.
----Respondents
D.B. Civil Writ Petition No. 199/2026
Girdhari Ram S/o Late Shri Chutra Ram, Aged About 73 Years,
Resident Of Village Gulasar, Gram Panchayat Birloka, Tehsil
Khinvsar, District Nagaur.
----Petitioner
Versus
1. The State Of Rajasthan, Through The Secretary And
Commissioner, Rural Development And Panchayati Raj
Department, Govt. Of Rajasthan, Secretariat, Jaipur.
2. The District Collector, Nagaur.
3. The Sub Division Officer, Khinvsar, District Nagaur.
----Respondents
D.B. Civil Writ Petition No. 279/2026
1. Mahavir Singh S/o Shri Mukan Singh, Aged About 40
Years, Resident Of Village Chaura, District Jalore.
2. Tulsa Ram S/o Shri Chhoga Ram, Aged About 50 Years,
Resident Of Village Chaura, District Jalore.
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3. Vana Ram S/o Shri Rayga Ram, Aged About 52 Years,
Resident Of Village Chaura, District Jalore.
4. Narana Ram S/o Shri Hema Ram, Aged About 52 Years,
Resident Of Village Chaura, District Jalore.
5. Jora Ram S/o Shri Naga Ram, Aged About 58 Years,
Resident Of Village Chaura, District Jalore.
----Petitioners
Versus
1. State Of Rajasthan, Through Secretary, Rural
Development And Panchayat Raj Department,
Government Of Rajasthan, Secretariat, Jaipur.
2. The District Collector, District - Jalore (Raj.)
3. The Tehsildar, Sanchore, District - Jalore (Raj.)
4. The Gram Panchayat Chora, Panchayat Samiti Sanchore,
District Jalore Through Its Sarpanch.
----Respondents
D.B. Civil Writ Petition No. 346/2026
1. Girdhari Lal S/o Sh. Panna Ram, Aged About 68 Years,
Resident Of Village Dhani Tetarwal, Tehsil Sardarshahar,
District Churu (Rajasthan).
2. Gugan Ram S/o Sh. Ravat Ram, Aged About 66 Years,
Resident Of Village Dhani Tetarwal, Tehsil Sardarshahar,
District Churu (Rajasthan).
----Petitioners
Versus
1. The State Of Rajasthan, Through Secretary, Rural
Development And Panchayati Raj Department, Jaipur.
2. The District Collector, Churu.
3. The Sub Divisional Officer, Sardarshahar, District Churu.
----Respondents
D.B. Civil Writ Petition No. 360/2026
1. Sayed Akhtar S/o Shri Machchu Khan, Aged About 47
Years, Resident Of Karakwal, Tehsil Merta District Nagaur.
2. Munir Khan Joya S/o Shri Umar Khan, Aged About 63
Years, Resident Of Karakwal, Tehsil Merta District Nagaur.
----Petitioners
Versus
1. The State Of Rajasthan, Through Secretary, Department
Of Rural Development And Panchayati Raj, Government
Of Rajasthan, Secretariat, Jaipur.
2. District Collector Cum District Election Officer, Nagaur.
3. Sub Divisional Officer, Merta, District Nagaur.
4. Shri Laxman Ram, Mla, Merta District Nagaur.
----Respondents
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D.B. Civil Writ Petition No. 426/2026
1. Likhma Ram S/o Shri Narayan Ram, Aged About 64 Years,
Resident Of Village Suratpura, Tehsil Makrana, District
Deedwana- Kuchaman, Rajasthan.
2. Hari Singh S/o Shri Indra Dan, Aged About 60 Years,
Resident Of Village Suratpura, Tehsil Makrana, District
Deedwana- Kuchaman, Rajasthan.
3. Bajrang Lal S/o Shri Lalu Ram, Aged About 51 Years,
Resident Of Village Suratpura, Tehsil Makrana, District
Deedwana- Kuchaman, Rajasthan.
4. Kana Ram S/o Shri Ganesha Ram, Aged About 47 Years,
Resident Of Village Suratpura, Tehsil Makrana, District
Deedwana- Kuchaman, Rajasthan.
5. Bhanwara Ram S/o Shri Pema Ram Jat, Aged About 65
Years, Resident Of Village Suratpura, Tehsil Makrana,
District Deedwana- Kuchaman, Rajasthan.
6. Jetha Ram S/o Shri Pusa Ram Prajapat, Aged About 68
Years, Resident Of Village Suratpura, Tehsil Makrana,
District Deedwana- Kuchaman, Rajasthan.
7. Peetha Ram S/o Shri Rugha Ram Jat, Aged About 65
Years, Resident Of Village Suratpura, Tehsil Makrana,
District Deedwana- Kuchaman, Rajasthan.
----Petitioners
Versus
1. State Of Rajasthan, Through The Principal Secretary,
Rural Development And Panchayati Raj Department,
Government Of Rajasthan, Secretariat, Jaipur, Rajasthan.
2. The Secretary Cum Commissioner, Department Of Rural
Development And Panchayati Raj Department,
Government Of Rajasthan, Secretariat, Jaipur, Rajasthan.
3. District Election Officer Cum District Collector, Deedwana-
Kuchaman, Rajasthan.
4. Sub Divisional Officer (Sdo), Makrana, District Deedwana-
Kuchaman, Rajasthan.
----Respondents
D.B. Civil Writ Petition No. 497/2026
1. Devaram Choudhary S/o Shri Shankar Lal Choudhary,
Aged About 33 Years, Resident Of Gram- Khor, Post-
Jalampur, Tehsil And District Chittorgarh.
2. Charan Singh S/o Shri Shankar Lal, Aged About 42 Years,
Resident Of Nayi Abadi Khor, Post- Jalampur, Tehsil And
District Chittorgarh.
----Petitioners
Versus
1. The State Of Rajasthan, Through Its Secretary,
Department Of Rural Development And Panchayati Raj,
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Government Of Rajasthan, Secretariate, Jaipur.
2. The Secretary (Administriative) And Commissioner,
Department Of Rural Development And Panchayati Raj
(Department Of Panchayati Raj), Government Of
Rajasthan, Jaipur.
3. The District Collector, Chittorgarh.
4. The Principal Secretary, Department Of Revenue,
Government Of Rajasthan, Secretariate, Jaipur.
5. The Sub-Divisional Officer, Tehsil- Chittorgarh, District-
Chittorgarh.
6. The Tehsildar (Land Record), Tehsil- Chittorgarh, District-
Chittorgarh.
----Respondents
D.B. Civil Writ Petition No. 522/2026
1. Ajit Singh Charan S/o Shri Himmat Singh Ji, Aged About
65 Years, Residents Of Village Jaitpura, Tehsil Asind,
District Bhilwara, Rajasthan.
2. Indarlal S/o Radheyshyam Dholi, Aged About 59 Years,
Residents Of Village Jaitpura, Tehsil Asind, District
Bhilwara, Rajasthan.
3. Shyamlal Balai S/o Shri Chunnilal Blai Ji, Aged About 42
Years, Residents Of Village Jaitpura, Tehsil Asind, District
Bhilwara, Rajasthan.
4. Shivlal Suthar S/o Shri Sohanlal Ji, Aged About 55 Years,
Residents Of Village Jaitpura, Tehsil Asind, District
Bhilwara, Rajasthan.
5. Kanhaiyalal Gurjar S/o Shri Bhiga Ji, Aged About 50
Years, Residents Of Village Jaitpura, Tehsil Asind, District
Bhilwara, Rajasthan.
6. Nanuram Balai S/o Shri Biramlal Ji, Aged About 37 Years,
Residents Of Village Jaitpura, Tehsil Asind, District
Bhilwara, Rajasthan.
----Petitioners
Versus
1. State Of Rajasthan, Through The Additional Chief
Secretary, Department Of Rural Development And
Panchayati Raj, Secretariat, Jaipur.
2. The Secretary And Commissioner, Department Of Rural
Development And Panchayati Raj, Secretariat Jaipur.
3. The Chief Executive Officer, Zila Parishad Bhilwara.
4. The District Collector, Bhilwara.
5. The Sub Divisional Officer, Tehsil Asind District Bhilwara.
6. The Tehsildar, Tehsil Asind District Bhilwara.
----Respondents
D.B. Civil Writ Petition No. 565/2026
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Ram Swaroop Kaswa S/o Hari Ram, Aged About 58 Years, R/o
Village Harsolav, Tehsil Gotan, District Nagaur (Raj.).
----Petitioner
Versus
1. State Of Rajasthan, Through Secretary, Department Of
The Panchayat Raj, Government Of Rajasthan, Jaipur.
2. District Collector, Nagaur.
3. Vikas Adhikari, Panchayat Samiti Merta, District Nagaur.
----Respondents
D.B. Civil Writ Petition No. 763/2026
1. Sahi Nath S/o Prem Nath, Aged About 54 Years, Resident
Of Patamdesar, District Churu Rajasthan.
2. Birbal Joshi S/o Aasu Ram, Aged About 50 Years,
Patamdesar, District Churu Rajasthan.
3. Tilokaram S/o Ganesha Ram, Aged About 54 Years,
Patamdesar, District Churu Rajasthan.
4. Mahaveer Prasad S/o Lekh Ram, Aged About 49 Years,
Patamdesar, District Churu Rajasthan.
----Petitioners
Versus
1. The State Of Rajasthan, Through Secretary To The
Government Commissioner, Rural Development
Panchayati Raj Department (Panchayati Raj), Government
Of Rajasthan, Secretariat, Jaipur.
2. District Collector, District Churu, Rajasthan.
----Respondents
D.B. Civil Writ Petition No. 926/2026
Kalwant Singh S/o Sh. Darshan Singh, Aged About 48 Years,
Resident Of Ward No. 7, 31 Ml, Ganganagar.
----Petitioner
Versus
1. State Of Rajasthan, Through Principal Secretary, Rural
Development And Panchayati Raj Department,
Government Of Rajasthan, Jaipur.
2. Department Of Revenue (Group-I), Government Of
Rajasthan, Jaipur, Through Joint Secretary.
3. District Collector, Ganganagar.
4. The Divsional Commissioner, Ganganagar.
5. Tehsildar (Land Revenue), Ganganagar.
----Respondents
D.B. Civil Writ Petition No. 1133/2026
1. Ramswaroop S/o Shri Nandram, Aged About 59 Years,
Resident Of Gram Saarsar, Gram Panchayat- Saarsar,
Tehsil- Sardarshahar, District Churu, 331402.
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2. Mamraj Saran S/o Shri Nandram Saran, Aged About 35
Years, Resident Of Gram- Saarsar, Gram Panchayat -
Saarsar, Tehsil- Sardarshahar, District- Churu, 331402.
----Petitioners
Versus
1. The State Of Rajasthan, Through Its Secretary,
Department Of Rural Development And Panchayati Raj,
Government Of Rajasthan, Secretariat, Jaipur.
2. The Secretary (Administrative) And Commissioner,
Department Of Rural Development And Panchayati Raj
(Department Of Panchayati Raj), Government Of
Rajasthan, Jaipur.
3. The District Collector, Churu.
4. The Principal Secretary, Department Of Revenue,
Government Of Rajasthan, Secretariat, Jaipur
5. The Sub Divisional Officer, Tehsil- Sardarshahar, District-
Churu.
6. The Tehsildar, (Land Record), Tehsil- Sardarshahar,
District- Churu.
----Respondents
D.B. Civil Writ Petition No. 1492/2026
1. Hara Ram S/o Taja Ram, Aged About 54 Years, Resident
Of Village Solankiya Talla, Tehsil Shergarh, District
Jodhpur.
2. Ishe Khan S/o Late Hazi Khan, Aged About 53 Years,
Resident Of Village Suryodaya Nagar, Tehsil Shergarh,
District Jodhpur.
3. Kanwrajdan S/o Vijaydan, Aged About 52 Years, Resident
Of Village Pugalia, Tehsil Shergarh, District Jodhpur.
4. Pempa Ram S/o Kheta Ram, Aged About 39 Years,
Resident Of Village Santoshnathpura, Tehsil Shergarh,
District Jodhpur.
5. Mana Ram S/o Hari Ram, Aged About 52 Years, Resident
Of Village Dashania, Tehsil Shergarh, District Jodhpur.
----Petitioners
Versus
1. The State Of Rajasthan, The Secretary And Commissioner,
Rural Development And Panchayati Raj Department, Govt.
Of Rajasthan, Secretariat, Jaipur.
2. The District Collector, Jodhpur.
----Respondents
D.B. Civil Writ Petition No. 2780/2026
1. Saddam Husain S/o Shri Hanif Khan, Aged About 30
Years, R/o 30, Teliyon Ka Bas, Nandiya Kalan, Tehsil
Baori, District Jodhpur, Rajasthan.
2. Chetan Ram S/o Shri Naru Ram, Aged About 57 Years, R/
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o Macharo Ki Dhaniyan, Nandiya Kalan, Tehsil Baori,
District Jodhpur, Rajasthan.
----Petitioners
Versus
1. State Of Rajasthan, Through Secretary And
Commissioner, Department Of Rural Development And
Panchayati Raj, Government Of Rajasthan, Secretariat,
Jaipur.
2. Deputy Secretary And Deputy Commissioner (First),
Department Of Rural Development And Panchayati Raj,
Government Of Rajasthan, Secretariat, Jaipur.
3. District Collector, Jodhpur.
4. Sub Divisional Officer, Baori, Jodhpur.
----Respondents
D.B. Civil Writ Petition No. 1825/2026
1. Chenpal Singh S/o Shri Prithvi Singh, Aged About 38
Years, R/o Raghunathpura, Tehsil Nava, District
Deedwana Kuchaman (Raj.).
2. Chennaram S/o Shri Chatraram, Aged About 43 Years,
R/o Raghunathpura, Tehsil Nava, District Deedwana
Kuchaman (Raj.).
3. Hanuman Ram S/o Shri Sheoram, Aged About 62 Years,
R/o Raghunathpura, Tehsil Nava, District Deedwana
Kuchaman (Raj.).
4. Mannaram S/o Shri Gordhanram, Aged About 35 Years,
R/o Devnagar, Tehsil Nava, District Deedwana
Kuchaman.
----Petitioners
Versus
1. State Of Rajasthan, Through The Principal Secretary,
Department Of Revenue, Government Of Rajasthan,
Jaipur (Raj.).
2. The Principal Secretary, Department Of Rural
Development And Panchayati Raj, Government Of
Rajasthan, Jaipur (Raj.).
3. The Deputy Commissioner Cum Deputy Secretary
(First), Department Of Rural Development And
Panchayati Raj, Government Of Rajasthan, Jaipur (Raj.).
4. The District Collector, Deedwana Kuchaman (Raj.).
5. The Chief Executive Officer, Zila Parishad,
Deedwanakuchaman (Raj.).
6. The Sub Divisional Officer, Tehsil Nava, District
Deedwana Kuchaman (Raj.).
7. The Tehsildar, Tehsil Nava, District Deedwana Kuchaman
(Raj.).
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----Respondents
D.B. Civil Writ Petition No. 1829/2026
1. Om Prakash S/o Shri Ramchandra, Aged About 55
Years, Resident Of Village 3 Jm, 20 Lm, 15 Lm, District
Sriganganagar (Rajasthan).
2. Kulwant Singh S/o Shri Chanan Singh, Aged About 65
Years, Resident Of 3 Jm, 20 Lm, District Sriganganagar
(Rajasthan).
3. Balvinder Singh S/o Shri Nakshatra Singh, Aged About
51 Years, Resident Of Village 3 Jm, 15 Lm, District
Sriganganagar (Rajasthan).
4. Dalip Kumar S/o Shri Jai Singh, Aged About 31 Years,
Resident Of Ward No. 1 P.o, 15 Lm, 3 Jm, Sriganganagar
(Rajasthan).
5. Angad Kumar S/o Shri Devi Lal, Aged About 56 Years,
Resident Of Village 3 Jm, 20 Lm, 15 Lm, District
Sriganganagar (Rajasthan.).
6. Ramchand S/o Shri Shrwam Ram, Aged About 75 Years,
Resident Of Ward No. 2, Village Chak 3 Jm, 15 Lm,
Sriganganagar (Rajasthan).
----Petitioners
Versus
1. The State Of Rajasthan, Through The Principal
Secretary, Department Of Rural Development And
Panchayati Raj, Government Of Rajasthan, Jaipur
(Rajasthan).
2. The Secretary-Cum-Commissioner, Department Of Rural
Development And Panchayati Raj, Government Of
Rajasthan, Jaipur (Rajasthan).
3. The District Election-Cum-District Collector,
Sriganganagar (Rajasthan).
4. The Sub Divisional Magistrate, Anoopgarh, District
Sriganganagar (Rajasthan).
5. The Gram Panchayat, Chak 1 Nwm Through Its
Administrator-Cum-Secretary, Tehsil Anoopgarh, District
Sri Ganganagar (Rajasthan).
6. The Gram Panchayat, Chak 15 Lm Through Its
Administrator-Cum-Secretary, Tehsil Anoopgarh, District
Sri Ganganagar (Rajasthan).
----Respondents
D.B. Civil Writ Petition No. 791/2026
1. Mukand Singh Mehra S/o Harnek Singh Mehra, Aged
About 57 Years, R/o Raisinghnagar, 5 Ksd-B,
Ganganagar,rajasthan-335051.
2. Ram Kumar S/o Hajari Ram, Aged About 54 Years, R/o
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Raisinghnagar, 5 Ksd-B, Ganganagar,rajasthan-
335051.
3. Amar Singh S/o Vijay Singh, Aged About 62 Years, R/o
80, 5 K.s.d.b, Tehsil Raisinghnagar, Dist
Shriganganagar, Rajasthan- 335051.
----Petitioners
Versus
1. The State Of Rajasthan, Through Its Secretary To The
Government, Rural Development Panchayati Raj
Department, Government Of Rajasthan, Jaipur.
2. The District Collector, Shri Ganganagar.
----Respondents
For Petitioner(s) : Mr. GR Punia, Sr. Advocate assisted
by Mr. Rajesh Punia
Mr. Moti Singh with
Mr. Siddharth Mewara
Mr. Gaurav Ranka for
Mr. Muktesh Maheshwari
Mr. Foja Ram
Mr. Sanjay Rewar
Mr. KR Saharan
Mr. Manish Patel
Mr. Mohit Sharma
Mr. Mohit Chaudhary
Mr. Jai Kishan Bhaiya
Mr. Rajat Rajpurohit for
Mr. Sajjan Singh
Mr. Lakshya Singh Udawat
Mr. Symer Singh Gaur
Mr. Jitendra Singh Bhanwariya
Mr. Kirta Ram Meghwal
Dr. Ashok Choudhary
Mr. Ravindra Kumar Acharya
Mr. Avinash Acharya
Mr. Devendra Singh Thind
Mr. Amit Kumar Sonika
Ms. Laxmi Rathore
For Respondent(s) : Mr. I.R. Choudhary, AAG with
Mr. Pawan Bharti,
Mr. Kuldeep Singh Solankiya
Mr. Rohit Choudhary
Ms. Richa Bohra & Ms. Bhawna Dave
Mr. Kunal Upadhyay
Mr. Ram Niwas Haniya
Mr. Arpit Samariya, AAAg for
Mr. Nathu Singh Rathore, AAG
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HON'BLE DR. JUSTICE PUSHPENDRA SINGH BHATI
HON’BLE MR. JUSTICE SANDEEP SHAH
Judgment
1. Date of conclusion of arguments 18.03.2026, 25.03.2026 &
27.03.2026
2. Date on which judgment was reserved 18.03.2026, 25.03.2026 &
27.03.2026
3. Whether the full judgment or only the Full Judgment
operative part is pronounced:
4. Date of pronouncement 13.04.2026
1. Delimitation and reorganization of Panchayati Raj Institutions
constitute a vital component of grassroots democratic governance,
having a direct bearing on representation, administrative
convenience and effective implementation of local self-government
envisaged under Part IX of the Constitution of India. The process,
by its very nature, involves evaluation of multiple factors such as
population, geographical contiguity, accessibility and availability of
infrastructure, and thus assumes considerable significance in
ensuring balanced and functional decentralization.
1.1. These writ petitions, though arising out of varying factual
backgrounds, were heard together, as they involve common
questions pertaining to the validity of notifications issued in the
course of such delimitation and reorganization exercise. Since the
issues involved are substantially overlapping and interconnected,
all the petitions are being decided by this common order.
1.2. It is also pertinent to note that the present batch of writ
petitions comprises multiple matters arising out of the delimitation
and reorganization exercise of Panchayati Raj Institutions
undertaken by the State Government. D.B. Civil Writ Petition Nos.
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23412/2025, 23361/2025, 199/2026, 279/2026, 346/2026,
360/2026, 426/2026, 497/2026, 522/2026, 565/2026, 763/2026,
926/2026, 1133/2026, 1492/2026 and 2780/2026 were reserved
for orders on 18.03.2026; D.B. Civil Writ Petition Nos. 1825/2026
and 1829/2026 were reserved subsequently on 25.03.2026; and
D.B. Civil Writ Petition No. 791/2026 was reserved thereafter on
27.03.2026. Since all the aforesaid writ petitions arise from the
same delimitation exercise and involve common and overlapping
questions of fact and law, they were heard analogously and are
being decided together by this common order for the sake of
convenience, judicial economy and to ensure consistency in
adjudication.
2. The petitioners, being aggrieved of the aforesaid exercise of
delimitation and reorganization undertaken by the State
Government, have preferred the present batch of writ petitions
seeking quashing and setting aside the notifications dated
20/21.11.2025, 28.12.2025 and 31.12.2025, issued by the State
Government under the provisions of the Rajasthan Panchayati Raj
Act, 1994, whereby various Panchayati Raj Institutions, including
Gram Panchayats and Panchayat Samitis, have been created,
altered, reconstituted, substituted, or their names and
headquarters modified, to the extent such actions are alleged to
have been undertaken without following the statutory procedure,
without inviting or considering objections, in deviation from the
notified proposals, in violation of applicable guidelines, or in
disregard of subsisting judicial orders.
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2.1. The petitions further seek consequential directions for
restoration of the position as emerging from the duly notified
proposals and/or the final notification dated 20/21.11.2025, and
for restraining the respondents from effecting any alteration in the
constitution, limits, name or headquarters of Panchayati Raj
Institutions except in accordance with law, particularly in
compliance with the requirements of Sections 9, 10 and 101 of the
Rajasthan Panchayati Raj Act, 1994 and the applicable policy
guidelines.
2.2. The petitions also seek declaration that the impugned actions
are arbitrary, unreasonable and violative of the principles of
natural justice and the mandate of Articles 14 and 243 of the
Constitution of India, along with all consequential and ancillary
reliefs.
3. Briefly stated, the facts giving rise to the present batch of
writ petitions are that the State Government initiated an exercise
for reorganization and delimitation of Panchayati Raj Institutions
pursuant to policy/guidelines issued in the year 2025, whereunder
the District Collectors were required to prepare proposals, invite
objections from the public and submit recommendations for
consideration at the State level. In furtherance thereof, proposals
were published, objections were invited and considered, and
thereafter notifications dated 20/21.11.2025 came to be issued
constituting, altering or reconstituting various Gram Panchayats
and Panchayat Samitis.
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3.1. In certain cases, the grievance of the petitioners is that the
final notification departed from the original proposal, inasmuch as
villages or areas proposed to be included in one Panchayat Samiti
or Gram Panchayat were ultimately included in a different unit,
without any fresh notice or opportunity of objection.
3.2. In another set of cases, the petitioners have assailed the
subsequent notifications dated 28.12.2025 and 31.12.2025,
contending that after culmination of the process and issuance of
the final notification, further alterations were carried out by way of
amendments/corrigenda, including change of name, inclusion or
exclusion of villages, alteration of headquarters and even
substitution or creation of new Panchayats, without undertaking
any fresh exercise of inviting objections.
3.3. In some of the petitions, it is alleged that the impugned
actions have been taken despite subsisting interim orders passed
by this Court in earlier proceedings, and that the subsequent
notifications indirectly seek to give effect to matters which were
already under judicial consideration.
3.4. Certain petitioners have also raised grievance that though
objections were invited, the same were not duly considered, and
the final decision has been taken without assigning reasons,
allegedly ignoring relevant factors such as distance, connectivity,
population, availability of infrastructure and administrative
convenience.
3.5. In a few cases, it is further contended that the impugned
actions are contrary to the policy guidelines issued by the State
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Government itself, and that the deviations effected in the final or
subsequent notifications are neither supported by the material on
record nor preceded by any discernible decision-making process.
3.6. Thus, though the individual facts vary from case to case, the
core challenge in the present batch revolves around the legality of
the process adopted by the State in issuing the impugned
notifications, particularly with regard to deviation from proposals,
post-notification alterations, alleged non-consideration of
objections, and the manner in which the reorganization exercise
has been carried out.
4. Learned counsel for the petitioners submitted that:
4.1. The entire exercise undertaken by the State Government in
issuing the impugned notifications is vitiated for non-compliance
of the mandatory statutory scheme under Sections 9, 10 and 101
of the Rajasthan Panchayati Raj Act, 1994, which unequivocally
requires publication of proposal, invitation of objections,
consideration thereof and only thereafter issuance of final
notification. It is submitted that in a large number of cases, the
impugned actions have been taken without issuance of any prior
notice or without affording opportunity to the affected inhabitants,
thereby rendering the action void ab initio.
4.2. Learned counsel submitted that the foundation of the entire
exercise lies in the proposal dated 07.04.2025, pursuant to which
objections were invited from the public. However, the final
notifications have travelled far beyond the scope of such
proposals, inasmuch as villages and areas which were never part
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[2026:RJ-JD:14200-DB] (15 of 23) [CW-23412/2025]of the proposal, or were proposed to be included in a different
Panchayat, have ultimately been included in entirely different
Gram Panchayats or Panchayat Samitis, without any fresh process.
It is contended that such deviation strikes at the very root of the
statutory requirement and defeats the purpose of inviting
objections.
4.3. It is further submitted that once the process culminated in
the issuance of final notification dated 20/21.11.2025, the State
Government became functus officio to the extent of that exercise,
and any further alteration could only have been made by initiating
a fresh exercise in accordance with law. However, the subsequent
notifications dated 28.12.2025 and 31.12.2025 have been issued
making substantive and far-reaching changes, including alteration
of territorial limits, change of name of Panchayats, shifting of
headquarters, substitution of one Panchayat by another and even
creation of entirely new Panchayats.
4.4. Learned counsel vehemently submitted that such subsequent
actions have been sought to be justified under the garb of
“corrigendum” or “clerical error”, whereas in reality, they amount
to fresh delimitation and reorganization, which is impermissible
without following the complete statutory procedure. It is
submitted that the power to correct clerical or typographical errors
cannot be stretched to undo a concluded exercise or to re-write
the delimitation itself.
4.5. It is also contended that in certain petitions, the impugned
actions have been taken despite subsisting interim orders passed
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by this Court, whereby the authorities were restrained from
proceeding further in respect of the concerned subject matter. It is
submitted that the subsequent notifications, though couched in a
different form, seek to indirectly achieve what could not be done
directly, and thus amount to an attempt to overreach the process
of the Court.
4.6. Learned counsel further submitted that even in cases where
objections were invited, the same have been mechanically dealt
with or not considered at all, and no reasoned decision-making
process is discernible from the record. It is submitted that the
requirement of inviting objections is not an empty formality, but
entails a corresponding duty to apply mind to the objections and
take an informed decision, which is conspicuously absent in the
present cases.
4.7. It is also urged that the impugned decisions suffer from
manifest arbitrariness and non-application of mind, inasmuch as
relevant factors such as population strength, geographical
contiguity, distance between villages, accessibility, availability of
infrastructure and administrative convenience have been ignored,
and in several instances, villages have been attached to distant or
non-contiguous Panchayats, leading to serious practical difficulties
for the inhabitants.
4.8. Learned counsel further submitted that the impugned actions
are also in the teeth of the policy guidelines issued by the State
Government itself, particularly the guidelines dated 10.01.2025,
which prescribe the criteria for creation, alteration and
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determination of headquarters of Panchayats. It is submitted that
deviation from such policy, without any recorded justification,
renders the decision arbitrary and violative of Article 14 of the
Constitution of India.
4.9. It is thus submitted that the impugned notifications, to the
extent they suffer from the aforesaid infirmities, are unsustainable
in law, and deserve to be quashed, with a direction to the
respondents to adhere to the statutory scheme and restore the
position as it existed upon completion of the lawful process
culminating in the notification dated 20/21.11.2025.
5. Learned counsel for the respondents, while opposing the
present batch of writ petitions, advanced elaborate submissions,
which, in essence, are as follows:
5.1. Learned counsel, at the outset, questioned the very
maintainability of the writ petitions, contending that the challenge
laid by the petitioners is directed against an exercise of
delimitation and reorganization of Panchayati Raj Institutions,
which stands protected from judicial interference by virtue of the
constitutional scheme contained under Articles 243-O and 243-ZG
of the Constitution of India, read with Section 117 of the
Rajasthan Panchayati Raj Act, 1994. It is submitted that once the
process culminates in a final notification, the jurisdiction of this
Court under Article 226 stands severely circumscribed.
5.2. Learned counsel submitted that the State Government has
undertaken a comprehensive and structured exercise of
reorganization, pursuant to policy decisions and guidelines issued
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[2026:RJ-JD:14200-DB] (18 of 23) [CW-23412/2025]in the year 2025, wherein District Collectors were entrusted with
the task of preparing proposals, inviting objections and forwarding
recommendations. It is urged that the process was carried out in a
multi-tiered manner, involving consideration at the district level as
well as scrutiny by a High-Level Committee at the State level,
thereby ensuring due application of mind at every stage.
5.3. It is further submitted that the allegations of the petitioners
regarding absence of notice or non-consideration of objections are
unfounded, inasmuch as public notices were duly issued,
objections were invited and considered, and the final decisions
were taken after evaluating relevant parameters such as
population, geographical contiguity, administrative feasibility and
overall governance considerations. It is contended that mere non-
acceptance of objections does not imply non-consideration.
5.4. Learned counsel emphasized that the process of delimitation
is in the nature of legislative or conditional legislative function,
which carries a presumption of validity and is ordinarily immune
from judicial review.
5.5. It is further submitted that this legal position has been
consistently followed by this Hon’ble Court in a catena of
decisions, including Sunil Jangid & Ors. v. State of Rajasthan
(D.B. Civil Writ Petition No. 988/2026 and other connected
matters decided on 21.02.2026), wherein a batch of writ
petitions raising similar challenges to the delimitation exercise
came to be dismissed, and such view has attained finality upon
affirmation by the Hon’ble Supreme Court.
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5.6. Learned counsel has also drawn the attention of this Court to
the judgment rendered by the Division Bench of this Hon’ble Court
in Mamta v. State of Rajasthan (D.B. Civil Writ Petition No.
14354/2019 and other connected matters decided on
26.02.2026), wherein a large number of writ petitions arising out
of restructuring of Panchayati Raj institutions were adjudicated
together and dismissed, reiterating that such policy-driven
administrative decisions warrant minimal judicial interference.
5.7. Learned counsel further placed strong reliance upon the
orders passed by the Hon’ble Supreme Court in Villagers of
Revenue Village Singhaniya & Anr. v. State of Rajasthan &
Ors. (Petition(s) for Special Leave to Appeal (C) No(s).
34/2026 [Arising out of impugned judgment and order
dated 14-11-2025 in DBCWP No. 8192/2025 passed by the
High Court of Judicature for Rajasthan at Jaipur] decided
on 05.01.2026), Jai Singh & Anr. v. State of Rajasthan &
Ors. (Petition(s) for Special Leave to Appeal (C)
No(s).4977/2026 [Arising out of impugned final judgment
and order dated 21-01-2026 in DBCWP No.792/2026
passed by the High Court of Judicature for Rajasthan at
Jaipur] decided on 16.02.2026) and Alkesh v. State of
Rajasthan & Ors. (Petition(s) for Special Leave to Appeal
(C) No(s).8148/2026 [Arising out of impugned final
judgment and order dated 21-01-2026 in DBCWP
No.299/2026 passed by the High Court of Judicature for
Rajasthan at Jaipur] decided on 09.03.2026), wherein the
Hon’ble Supreme Court, while dealing with challenges arising out
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[2026:RJ-JD:14200-DB] (20 of 23) [CW-23412/2025]
of the very same delimitation exercise, has declined to interfere
and has observed that no infringement of any constitutional or
legally vested right is made out, while also granting liberty to the
aggrieved parties to approach the competent authority for
redressal of their grievances.
5.8. Learned counsel further submitted that it is a settled
proposition of law that no individual or group of villagers has a
vested right to claim inclusion in a particular Gram Panchayat or
Panchayat Samiti, and the delimitation exercise, being policy-
oriented, cannot be tested on the touchstone of individual
convenience or preference.
5.9. With regard to the challenge based on alleged violation of
guidelines, it is submitted that the guidelines relied upon by the
petitioners are merely directory in nature, meant to guide
administrative discretion, and do not create enforceable rights. It
is urged that unless a clear case of arbitrariness or mala fide is
demonstrated, deviation, if any, cannot invalidate the entire
exercise.
5.10. Learned counsel also addressed the grievance regarding the
subsequent notifications dated 28.12.2025 and 31.12.2025,
contending that the same are in the nature of corrigenda, issued
to rectify clerical errors, inadvertent omissions and minor
inconsistencies arising in the earlier notifications, including
corrections based on representations received from stakeholders.
It is submitted that such corrections do not amount to a fresh
exercise of delimitation.
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5.11. It is further submitted that the doctrine of functus officio has
no application in the present context, as the State retains the
authority to effect necessary corrections and clarifications in the
notification till the commencement of the election process,
particularly where such corrections are intended to remove
ambiguities and facilitate smooth conduct of elections.
5.12. Learned counsel emphasized that the impugned notifications
and subsequent corrigenda have been issued prior to the
commencement of the election process and within the time frame
fixed, and therefore the same cannot be said to be without
jurisdiction.
5.13. It is also contended that the election process has already
been set in motion, voter lists have been finalized and wards have
been constituted, and any interference at this stage would
seriously disrupt the electoral process and defeat the
constitutional mandate of timely elections to local bodies.
5.14. Learned counsel thus submitted that even assuming limited
judicial review is available, the same is confined only to cases of
patent lack of jurisdiction, mala fides or manifest arbitrariness,
none of which are made out in the present batch of cases.
5.15. In light of the aforesaid submissions, it is urged that the
impugned notifications represent a lawful exercise of statutory
power undertaken in public interest, and the present writ
petitions, being devoid of merit and barred by constitutional
limitations, deserve to be dismissed.
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6. Heard counsel for the parties, perused the material available
on record and the judgments cited at the Bar.
6.1. This Court observes that the controversy involved in the
present batch of writ petitions pertains to the delimitation and
reorganization of Panchayati Raj Institutions undertaken by the
State Government, including the issuance of notifications dated
20/21.11.2025, 28.12.2025 and 31.12.2025.
6.2. This Court further observes that though the petitioners have
raised multiple grounds, including deviation from proposals, post-
notification alterations, non-consideration of objections, violation
of interim orders and alleged departure from policy guidelines, the
core issue relating to validity of such delimitation exercise is no
longer res integra.
6.3. This Court finds that an identical set of issues arising out of
the very same delimitation exercise has already been considered
and conclusively decided by a Coordinate Bench of this Hon’ble
Court in Mamta v. State of Rajasthan & Ors. (D.B. Civil Writ
Petition No. 14354/2019 decided on 26.02.2026).
6.4. This Court further finds that the Coordinate Bench in Mamta
(supra), after considering the entire spectrum of such challenges,
has declined to interfere and has upheld the validity of the
delimitation exercise, while also emphasizing that such matters
fall within the domain of administrative discretion and policy.
6.5. This Court finds that despite elaborate submissions, learned
counsel for the petitioners have not been able to demonstrate any
distinguishing feature, either on facts or in law, so as to take the
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present batch of cases outside the ambit of the judgment in
Mamta (supra) and the binding precedents noticed therein.
6.6. This Court observes that judicial discipline requires that a
Coordinate Bench follow an earlier judgment on identical issues
unless there exist compelling reasons to take a different view. This
Court thus finds that the present batch of writ petitions is squarely
covered by the judgment in Mamta (supra) and the consistent
line of precedents, and therefore does not warrant any
independent or fresh adjudication.
6.7. This Court further observes that the scope of judicial review
in matters of delimitation is extremely limited and confined to
cases of manifest arbitrariness, mala fide exercise of power or
jurisdictional error, none of which have been established in the
present cases.
7. Consequently, the present batch of writ petitions stands
dismissed. All pending applications, if any, stand disposed of.
(SANDEEP SHAH),J (DR.PUSHPENDRA SINGH BHATI),J
SKant/-
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