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Land Judgments · Rajasthan

Section 42, Rajasthan Tenancy Act: The Risk in Buying SC/ST Khatedari Landराजस्थान काश्तकारी अधिनियम धारा 42 — एससी/एसटी खातेदारी ज़मीन ख़रीदने का जोखिम

Companies, housing societies, decrees and long possession: every route around Section 42 that the courts have closed.

Not legal advice. AgriZameen is an independent private platform — not a government body, not a law firm, and not affiliated with any court or land-records department. This page summarises judgments in plain language for learning. Read the judgment itself and take advice from a licensed advocate before you act on it. Checked 26 September 2026.

Section 42 of the Rajasthan Tenancy Act, 1955 protects land held by Scheduled Caste and Scheduled Tribe khatedars: a sale, gift or bequest by an SC khatedar to someone who is not SC, or by an ST khatedar to someone who is not ST, is void. The courts have closed every route around it that buyers have tried — companies, housing societies, decrees, and simply waiting.

The short answer

The Section 42 check, before any payment
  1. The khatedar’s categoryRead it in the jamabandi, for every recorded holder.
  2. Every earlier transferA void link anywhere breaks the chain.
  3. How you are buyingCompany, society, relative or decree — none avoids the bar.
  4. An advocate’s viewWritten, dated and on this chain.

Companies and housing societies

In State of Rajasthan v. Aanjaney Organic Herbal (20 September 2012) a Scheduled Caste khatedar sold land to a company. The Supreme Court held that Section 42(b) covers a company or other juristic person: the sale was void and mutation was rightly refused. In Rajasthan Housing Board v. New Pink City Nirman Sahkari Samiti (2015) SC khatedars had agreed to sell their land to a housing society, some of whose members were themselves SC. The Court held the agreements void, and when the land was later acquired, only the khatedars or their heirs could claim compensation.

Time does not cure it

In Anandi Lal v. Dalip Prajapat, Tehsildar (3 February 2025) buyers who had held land for decades after buying it from a Scheduled Caste khatedar asked to be recorded as khatedars by adverse possession. The Rajasthan High Court refused: a person who purchased in breach of Section 42 cannot acquire khatedari rights by adverse possession, and long possession does not cure a void transfer.

Decrees

In Pooran Singh v. State (29 July 2026) a 1971 decree had declared the petitioners khatedars of land whose recorded khatedar was a Scheduled Caste member. The Board of Revenue treated the decree as a transfer barred by Section 42, and the Rajasthan High Court dismissed the writ: consent or waiver cannot defeat the statutory bar, and finality does not protect a void decree.

How far does the bar reach? A point still pending

In LRs of Teja Ram v. State of Rajasthan (2019) the Rajasthan High Court held that the bar covers a transfer by an SC/ST khatedar even to a body that has no caste, such as a municipal board. The Supreme Court granted leave and stayed that judgment on 13 July 2020, and as far as we can find the appeal has not been decided. Treat the point as unsettled. For companies, the Supreme Court’s own ruling in Aanjaney settles the question.

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.

Recent rulings, 2025–2026

What to check before you buy

Tools that help: SC/ST land rules in Rajasthan · Khatedari rights explained · Section 42, in the Academy encyclopaedia

What this guide cannot tell you

Section 42 has related provisions — including a narrow discretionary mechanism and restoration and ejectment routes — that this page does not set out; the SC/ST land rules page covers them. Category status is established by a competent authority, not by a surname or a record entry. Take an advocate’s opinion on the specific chain of title.

FAQ · अक्सर पूछे सवाल

Can a non-SC buyer purchase agricultural land from an SC khatedar in Rajasthan?

Section 42(b) of the Rajasthan Tenancy Act bars such a transfer. In Aanjaney Organic Herbal (2012) the Supreme Court held the sale void, and held that a company is covered by the bar.

If I have held such land for many years, do I become the khatedar?

No. In Anandi Lal (2025) the Rajasthan High Court held that a person who bought land in breach of Section 42 cannot claim khatedari rights by adverse possession.

Does Section 42 cover a sale to a municipal board or a body with no caste?

The Rajasthan High Court held so in Teja Ram (2019), but the Supreme Court stayed that judgment in July 2020 and, as far as we can find, has not decided the appeal. Treat the point as unsettled.

Sources

  1. State of Rajasthan v. Aanjaney Organic Herbal Pvt. Ltd. — Judgment text · Indian Kanoon.
  2. Rajasthan Housing Board v. New Pink City Nirman Sahkari Samiti Ltd. — Judgment text · Indian Kanoon.
  3. LRs of Teja Ram v. State of Rajasthan — Judgment text · Indian Kanoon.
  4. Anandi Lal v. Dalip Prajapat, Tehsildar — Judgment text · Indian Kanoon.
Keep going: All 83 land judgments · Recent rulings · Charagah, Ponds and Village Commons · 90-A Conversion and Master Plans · Buying checklist
Please note: AgriZameen is an independent, private information platform — not a government body, not a law firm, and not affiliated with any court or land-records department. These are plain-language summaries of court rulings for learning, checked on 26 September 2026; the law changes and a summary can be wrong. Read the judgment itself and consult a licensed advocate before you act. Nothing here is legal, tax or investment advice — land is market-linked and returns are never guaranteed.
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