Agricultural land in Rajasthan stays agricultural until it is converted under Section 90-A of the Rajasthan Land Revenue Act, 1956, and conversion inside a planned area has to fit the master plan. The Gulab Kothari judgments of the Rajasthan High Court made the master plan binding. In July 2026 the High Court held a 90-A conversion and patta on green-belt land void, whatever the buyer had paid.
The short answer
- Master plans must be followed faithfully; ecological zones, green belts and reserved open spaces are protected (Gulab Kothari, 2017).
- Conversion and regularisation of unauthorised colonies should wait for notified zonal and sector plans (Gulab Kothari, 2018) — though zonal plans are now optional for urban areas under one lakh population.
- The State may regularise unconverted non-agricultural use, but not against the plan, and reserved land cannot be leased (Bhanwar Singh, 2022).
- A 90-A conversion and patta on master-plan green belt are void; registration and good faith do not save them (Vikas Modi, 2026).
- Near sanctuaries, earlier conversions do not authorise new building without environmental clearance (Udaipur, 2026).
- Master plan useWhat the plan shows for this khasra.
- Zonal or sector planNotified, or still to come.
- The 90-A orderWho issued it, for what use, on what conditions.
- Other overlaysEco-sensitive zone, acquisition, RIICO land.
The Gulab Kothari line
The case began in 2004 when the Rajasthan High Court treated a letter from the editor of Rajasthan Patrika as a public interest petition about violations of city master plans. In its judgment of 12 January 2017 a Division Bench held that master development plans must be followed faithfully: land marked as ecological zone, green belt or peripheral belt should not be changed; parks, playgrounds and open spaces reserved in the plan must be preserved; and change of land use is allowed only as an exception, following the statutory procedure and in genuine public interest.
The State appealed. By the High Court’s own later account, the Supreme Court sent the matter to a three-judge bench of the High Court, which in its order of 15 December 2018 refused to relax the directions. It refused compounding of buildings that break bye-law limits such as building lines and setbacks, and said land-use conversion and regularisation of unauthorised colonies should not be permitted until zonal and sector plans are prepared and notified. Check whether any later Supreme Court appeal affects these directions before relying on them.
Regularisation and its limits
In Bhanwar Singh v. State of Rajasthan (9 February 2022) the High Court upheld the State’s 2021 campaign to regularise agricultural land put to non-agricultural use without permission, within limits: where the use conflicts with the sanctioned development plan, regularisation must strictly follow Gulab Kothari, and reserved or public-utility land cannot be leased. The same judgment noted an amendment making zonal plans optional for urban areas with under one lakh population, so the zonal-plan condition may not apply in small towns. Check the rules for the specific town.
A conversion is not a safe harbour
In Vikas Modi v. State of Rajasthan (17 July 2026) a buyer held a municipal patta issued after a Section 90-A conversion, but the land lay in the Alwar Master Plan-2031 green belt. The High Court upheld cancellation of the patta: master plans bind all authorities, a conversion contrary to them is void, and neither registration, good faith nor estoppel can validate it. It also ordered inquiries against the officers involved. In September 2026, in a batch of cases near Udaipur’s Sajjangarh sanctuary, the High Court held that earlier land conversions and building approvals do not authorise expansion within the eco-sensitive zone without environmental clearance.
Two other recent matters show how many layers can sit on one parcel. The Jaipur acquisition that lapsed in May 2026 (see the acquisition explainer) left the land agricultural, needing 90-A conversion before any other use. And a public interest petition challenging the Rajasthan Land Revenue (Amendment) Act, 2025 — whose new Section 100A deems land at RIICO’s disposal vested in RIICO and validates its past acts — is pending; in March 2026 the High Court directed that action under the amendment will abide by the outcome.
The judgments behind this guide
Each links to its full entry in the land judgments register, with the bench, the citation, where the ruling stands today and the sources.
- Gulab Kothari v. State of Rajasthan (2017) — Rajasthan High Court, 12 January 2017. Good law.
- Gulab Kothari v. State of Rajasthan (three-judge bench, 2018) — Rajasthan High Court, 15 December 2018. Good law.
- Bhanwar Singh v. State of Rajasthan — Rajasthan High Court, 9 February 2022. Good law.
Recent rulings, 2025–2026
- 1 September 2026 · Rajasthan High Court — Rajasthan HC: prior conversions don't permit building in Sajjangarh eco-sensitive zone. What it means and the source
- 17 July 2026 · Rajasthan High Court — Rajasthan HC: 90-A conversion of master-plan green belt is void; good faith no defence. What it means and the source
- 2 March 2026 · Rajasthan High Court — Rajasthan HC: RIICO land actions under new Section 100A subject to PIL outcome. What it means and the source
What to check before you buy
- Check the master plan and any zonal plan land use for the khasra yourself; do not rely on the seller or the patta.
- Treat land shown as green belt, ecological zone, park or facility area as not convertible, whatever papers exist.
- Read the 90-A order itself: who issued it, for what use, and on what conditions.
- Check for eco-sensitive zones, notified acquisitions and RIICO land before relying on any conversion.
Tools that help: Master plans in Rajasthan · Section 90-A conversion, step by step · Rural land conversion rules, 2007 · Gulab Kothari, in the Academy case library
What this guide cannot tell you
Conversion rules, fees and the planning status of individual towns change, and this page does not set them out. A master plan must be read at the level of the khasra; take advice from a planner or advocate on any specific parcel.
FAQ · अक्सर पूछे सवाल
Can land shown as green belt in the master plan be converted under Section 90-A?
The Rajasthan High Court held in Vikas Modi (July 2026) that a 90-A conversion and patta contrary to the master plan’s green belt are void, and that registration or the buyer’s good faith cannot validate them. The Gulab Kothari judgments (2017, 2018) hold master plans binding.
Does a converted plot near a sanctuary mean I can build?
Not by itself. In a 2026 Udaipur case the Rajasthan High Court held that earlier conversions and approvals do not authorise expansion within an eco-sensitive zone without environmental clearance.
Is a zonal plan required before conversion in every town?
The 2018 Gulab Kothari order required notified zonal and sector plans first, but a later amendment makes zonal plans optional for urban areas with under one lakh population, as the High Court noted in Bhanwar Singh (2022). Check the rules for the specific town.
Sources
- Gulab Kothari v. State of Rajasthan (2017) — Judgment copy · CourtKutchehry.
- Gulab Kothari v. State of Rajasthan (three-judge bench, 2018) — Bhanwar Singh (2022), quoting it · Indian Kanoon.