यह पेज हिंदी में पढ़ें →
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.
Most land disputes in India turn on a handful of rules the courts have settled over decades: a registered sale deed transfers land and an agreement does not; a mutation records who pays revenue but proves no ownership; common land cannot be bought from whoever occupies it; SC/ST khatedari land in Rajasthan cannot be sold outside the category. This register collects the judgments behind those rules, and the newer ones that are still moving.
83judgments and orders
73from the Supreme Court
22decided in or about Rajasthan
4still moving — stayed, recalled, on hold or interim
Start with a plain-language guide
Eleven explainers walk through the rules case by case, with what a buyer should check. The full register follows below them.
GPA, Agreement to Sell or RegistryOnly a registered sale deed transfers land. What Suraj Lamp, Shakeel Ahmed and the 2025 rulings say about GPA sales, agreements and the registry.9 judgments · Read the guide →Jamabandi and MutationA mutation neither creates nor ends ownership. Sawarni to Tarachandra (2025), and the Rajasthan rulings on which court hears what.6 judgments · Read the guide →Kabza and Adverse PossessionWhen long occupation can become ownership and when it cannot. Ravinder Kaur Grewal, Harphool Singh, Poona Ram and the 2026 ruling on hostility.10 judgments · Read the guide →Article 300A and the Right to PropertyWhat Article 300A protects: Jilubhai, K.T. Plantation, Vidya Devi and the seven sub-rights the State owes an owner (2024).12 judgments · Read the guide →Land Acquisition and CompensationWhen an old acquisition lapses, when urgency can skip a hearing, why buying under notification is a trap, and how farmland is valued.11 judgments · Read the guide →Inheritance and Family LandDaughters’ coparcenary rights, co-heirs’ first right to buy farmland, proving a will and family settlements — with 2025–2026 rulings.10 judgments · Read the guide →Agreement to Sell and Specific PerformanceWhat courts ask when a seller backs out: readiness and willingness, delay, earnest money, later buyers and the 2018 amendment.3 judgments · Read the guide →Charagah, Ponds and Village CommonsCharagah, ponds and nalas are held for the public. Jagpal Singh, the Rajasthan land protection cells and the 2026 catchment orders.8 judgments · Read the guide →Section 42 and SC/ST Khatedari LandSales of SC/ST khatedari land outside the category are void. Aanjaney, New Pink City, Anandi Lal (2025) and what is still pending.4 judgments · Read the guide →90-A Conversion and Master PlansThe Gulab Kothari line: master plans bind, green belt conversions are void (2026), and when zonal plans are needed.3 judgments · Read the guide →Sambhar, Orans, Aravalli and the BustardSambhar wetland orders and solar conditions, orans as forest, the Aravalli definition on hold and the bustard priority areas.6 judgments · Read the guide → Recent rulings, 2025–2026
Judgments reported since January 2025 that confirm, qualify or change the rules below. Each links to its source.
All 58 recent rulings and updates, by theme →
The register
Every entry gives the court, the bench, the date and the citation, what the court held, why it matters to a buyer, and where the ruling stands today. Filter by theme, show only rulings decided in or about Rajasthan, or search by a case name or a word such as mutation or charagah.
No judgment matches that. Try a shorter word — GPA, mutation, pond, daughter — or clear the filters.
Buying land: title documents and registration
ख़रीद: टाइटल के दस्तावेज़ और रजिस्ट्री
Who becomes the owner, and when. The answer has not moved in fifty years: an agreement, a power of attorney or a will does not transfer land. A registered sale deed does. Read the explainer →
Suraj Lamp & Industries (P) Ltd. v. State of Haryana
Supreme Court of India · R.V. Raveendran, A.K. Patnaik, H.L. Gokhale, JJ. (3 judges) · Decided 11 October 2011 · SLP (C) 13917/2009 · (2012) 1 SCC 656; AIR 2012 SC 206
Good lawSupreme Court · 2011
What the court held. A sale agreement, a general power of attorney and a will (the "SA/GPA/Will" route), used alone or together, is not a transfer and passes no title. Immovable property is conveyed only by a registered deed. Genuine powers of attorney for managing property are unaffected, and such documents can still support a suit for specific performance or a Section 53A defence of possession.
Why it matters to a buyer. The core warning for anyone offered land "on GPA": the buyer does not become the owner.
Where it stands. Good law. Reaffirmed in Shakeel Ahmed (2023), and applied again in Ramesh Chand v. Suresh Chand (1 Sep 2025). Not to be confused with the earlier 2009 order in the same matter.
Sources: Judgment text · Indian Kanoon · Case comment · SCC Online
Academy case study · Read the explainer
Shakeel Ahmed v. Syed Akhlaq Hussain
Supreme Court of India · Vikram Nath, Rajesh Bindal, JJ. · Decided 1 November 2023 · CA 1598/2023 · 2023 INSC 1016; 2023 SCC OnLine SC 1526
Good lawSupreme Court · 2023
What the court held. An unregistered agreement to sell or an unregistered power of attorney cannot pass title, and even a registered agreement to sell gives only a right to sue for specific performance. Suraj Lamp states the existing law; it is not merely prospective.
Why it matters to a buyer. Closes the argument that Suraj Lamp only affects deals made after 2011.
Where it stands. Good law. The Supreme Court relied on it in 2025 (Cosmos Co-operative Bank v. Central Bank of India, 4 Feb 2025; Vinod Infra Developers v. Mahaveer Lunia, 23 May 2025).
Sources: Supreme Court copy · Summary · Supreme Court Cases
Read the explainer
Ghanshyam v. Yogendra Rathi
Supreme Court of India · Pankaj Mithal, Dipankar Datta, JJ. · Decided 2 June 2023 · CA 7527-7528/2012 · (2023) 7 SCC 361
Good lawSupreme Court · 2023
What the court held. An agreement to sell, a power of attorney that never led to a registered sale deed, or a will while its maker is alive does not make anyone the owner. But a buyer who paid the full price and was lawfully put in possession under the agreement can defend that possession under Section 53A of the Transfer of Property Act against the seller and those claiming through him. The buyer, Yogendra Rathi, was the respondent and won.
Why it matters to a buyer. Shows the narrow protection an agreement or GPA buyer in possession does get: possession, not ownership.
Where it stands. Good law. Ramesh Chand v. Suresh Chand (2025 INSC 1059, 1 Sep 2025) repeats that Section 53A helps only a buyer who proves he was actually given possession. The Supreme Court copy is marked non-reportable, though the case is reported in SCC.
Sources: Supreme Court copy · Judgment text · Indian Kanoon
Read the explainer
Satya Pal Anand v. State of Madhya Pradesh
Supreme Court of India · A.M. Khanwilkar, Prafulla C. Pant, Ranjan Gogoi, JJ. (3 judges, on reference) · Decided 26 October 2016 · CA 6673/2014 · (2016) 10 SCC 767; AIR 2016 SC 4995
Good lawSupreme Court · 2016
What the court held. Once a document is registered, the Registration Act, 1908 gives neither the Sub-Registrar nor the Inspector General power to cancel it. Anyone challenging a registered deed must go to a civil court or another competent forum.
Why it matters to a buyer. Explains why a disputed registered sale deed cannot be undone at the registry office.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
Read the explainer
State of Rajasthan v. Basant Nahata
Supreme Court of India · Ashok Bhan, S.B. Sinha, JJ. · Decided 7 September 2005 · CA 7800/2001 · (2005) 12 SCC 77; AIR 2005 SC 3401
Good lawRajasthanSupreme Court · 2005
What the court held. Section 22-A, which Rajasthan added to the Registration Act in 1976 so that the State could refuse to register documents it declared "opposed to public policy", was struck down as an unguided power the legislature could not delegate. The notifications made under it, which had restricted registering certain property powers of attorney, fell with it.
Why it matters to a buyer. A Rajasthan case on the limits of the State’s power to refuse registration. It does not describe today’s Rajasthan registration rules.
Where it stands. Good law. Cited with approval by the Supreme Court in M.S. Ananthamurthy v. J. Manjula (27 Feb 2025).
In Rajasthan. Arose in Rajasthan.
Sources: Judgment text · Indian Kanoon · Summary · LawyersClubIndia
Read the explainer
Prem Singh v. Birbal
Supreme Court of India · S.B. Sinha, P.K. Balasubramanyan, JJ. · Decided 2 May 2006 · CA 2412/2006 · (2006) 5 SCC 353; AIR 2006 SC 3608
Good lawSupreme Court · 2006
What the court held. A registered document is presumed to be validly executed, and whoever challenges it must rebut that presumption. Article 59 of the Limitation Act governs suits to cancel voidable documents; a document that is void from the start needs no decree cancelling it.
Why it matters to a buyer. Why delay defeats challenges to old sale deeds, and the difference between a void deed and a voidable one.
Where it stands. Good law. The Supreme Court drew the same line in Shanti Devi v. Jagan Devi (12 Sep 2025).
Sources: Judgment text · Indian Kanoon · Commentary · Indian Law Live
Read the explainer
Narandas Karsondas v. S.A. Kamtam
Supreme Court of India · A.N. Ray CJ, M.H. Beg, Jaswant Singh, JJ. · Decided 7 December 1976 (reported 1977) · CA 1020/1975 · (1977) 3 SCC 247; AIR 1977 SC 774
Good lawSupreme Court · 1976
What the court held. Under Section 54 of the Transfer of Property Act a contract for sale does not by itself create any interest in, or charge on, the property. Ownership passes only on completion by a registered conveyance.
Why it matters to a buyer. The foundational rule behind "an agreement is not a sale". The main issue in the case was a mortgagor’s right to redeem.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Report · LatestLaws
Read the explainer
K.B. Saha and Sons Pvt. Ltd. v. Development Consultant Ltd.
Supreme Court of India · Tarun Chatterjee, A.K. Mathur, JJ. · Decided 12 May 2008 · CA 5659-5660/2002 · (2008) 8 SCC 564
Good lawSupreme Court · 2008
What the court held. An unregistered document that had to be registered can be used only for a genuinely collateral purpose, never to prove a key term of the transaction that needed registration.
Why it matters to a buyer. Why an unregistered lease or possession letter cannot prove your rights in court.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Later judgment citing it · Indian Kanoon
Read the explainer
Anathula Sudhakar v. P. Buchi Reddy
Supreme Court of India · R.V. Raveendran, P. Sathasivam, JJ. · Decided 25 March 2008 · CA 6191/2001 · (2008) 4 SCC 594; AIR 2008 SC 2033
Good lawSupreme Court · 2008
What the court held. A suit for a bare injunction is enough only for a plaintiff in lawful, peaceful possession. Where title is disputed or clouded, the plaintiff must sue for a declaration of title with possession or injunction; title is examined in an injunction suit only when it is properly pleaded and put in issue.
Why it matters to a buyer. Choosing the right suit when a neighbour or relative disputes your land.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Summary · Drishti Judiciary
Read the explainer
Revenue records and mutation
राजस्व रिकॉर्ड और नामांतरण
The jamabandi records who pays land revenue. It is the first paper a buyer checks, but the Supreme Court has said again and again that a mutation neither creates ownership nor ends it. Read the explainer →
Sawarni v. Inder Kaur
Supreme Court of India · G.B. Pattanaik, K. Ramaswamy, JJ. · Decided 23 August 1996 · (1996) 6 SCC 223; AIR 1996 SC 2823
Good lawSupreme Court · 1996
What the court held. Mutation in revenue records neither creates nor extinguishes title and has no presumptive value on title. It only makes the person in whose favour it is ordered liable to pay land revenue.
Why it matters to a buyer. The starting point for every "but my name is in the jamabandi" dispute.
Where it stands. Good law. Repeated by the Supreme Court in Karam Singh v. Amarjit Singh (15 Oct 2025).
Sources: Judgment text · Indian Kanoon · Later judgment applying it · Indian Kanoon
Read the explainer
Suraj Bhan v. Financial Commissioner
Supreme Court of India · C.K. Thakker, P.K. Balasubramanyan, JJ. · Decided 16 April 2007 · CA 1971/2007 · (2007) 6 SCC 186
Good lawSupreme Court · 2007
What the court held. Entries in revenue records or the jamabandi serve only a fiscal purpose and do not confer ownership. Title can be decided only by a competent civil court.
Why it matters to a buyer. Why revenue courts and tehsil records cannot settle who owns the land.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Later order citing it · Indian Kanoon
Read the explainer
Jitendra Singh v. State of Madhya Pradesh
Supreme Court of India · M.R. Shah, Aniruddha Bose, JJ. · Decided 6 September 2021 · SLP (C) 13146/2021 (order dismissing the petition) · 2021 SCC OnLine SC 802
Good lawSupreme Court · 2021
What the court held. In an order dismissing a special leave petition, the Court repeated that a mutation entry is kept only for revenue purposes and makes no one the owner. Where ownership is disputed, especially when mutation is sought on the strength of a will, the claimant must first establish his rights in a civil court.
Why it matters to a buyer. Mutation on the strength of a will: what revenue officers can and cannot do.
Where it stands. Good law, but read with Tarachandra v. Bhawarlal (2025 INSC 1485, December 2025): the Supreme Court said this order does not bar mutation on a will that no legal heir disputes, and that a will-based mutation must be considered on its merits.
Sources: Judgment text · Indian Kanoon · Report · SCC Online · Tarachandra (2025) · Verdictum
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Bhimabai Mahadeo Kambekar v. Arthur Import & Export Co.
Supreme Court of India · A.M. Sapre, R. Subhash Reddy, JJ. · Decided 31 January 2019 · CA 1330/2019 · (2019) 3 SCC 191; AIR 2019 SC 719
Good lawSupreme Court · 2019
What the court held. Restates that mutation neither creates nor extinguishes title and has no presumptive value on title; it only lets the person pay land revenue.
Why it matters to a buyer. A recent reaffirmation to read alongside Sawarni.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Summary · Legal Street
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Vishwa Vijai Bharti v. Fakhrul Hasan
Supreme Court of India · Y.V. Chandrachud, P.N. Shingal, JJ. · Decided 4 May 1976 · CA 1122-1123/1970 · (1976) 3 SCC 642; AIR 1976 SC 1485
Good lawSupreme Court · 1976
What the court held. Genuine entries in revenue records are ordinarily accepted at face value. But an entry that is forged or fraudulent, or was made surreptitiously, gets no such presumption and cannot support a claim to possessory title.
Why it matters to a buyer. When revenue entries help you, and when a fraudulent entry is worthless.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Later judgment quoting it · Indian Kanoon
Read the explainer
Balwant Singh v. Daulat Singh
Supreme Court of India · A.S. Anand, K. Venkataswami, JJ. · Decided 7 July 1997 · CA 293/1984 · (1997) 7 SCC 137; AIR 1997 SC 2719
Good lawSupreme Court · 1997
What the court held. A mutation recorded in others’ favour did not take away the widow’s title. Mutation has no presumptive value on title and only fixes who pays land revenue.
Why it matters to a buyer. Shows that a mutation cannot quietly strip an owner of land.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Later judgment applying it · Indian Kanoon
Read the explainer
Possession and adverse possession
क़ब्ज़ा और प्रतिकूल क़ब्ज़ा
Long occupation can, in narrow cases, become ownership. The courts set a high bar for it, and a higher one against government land. Read the explainer →
Ravinder Kaur Grewal v. Manjit Kaur
Supreme Court of India · Arun Mishra, S. Abdul Nazeer, M.R. Shah, JJ. (3 judges) · Decided 7 August 2019 · CA 7764/2014 · (2019) 8 SCC 729; AIR 2019 SC 3827
Good lawSupreme Court · 2019
What the court held. A person who has perfected title by adverse possession can sue as plaintiff for a declaration of title, an injunction or recovery of possession. The plea can be used to bring a claim, not only to defend one. Gurudwara Sahib (2013) was overruled.
Why it matters to a buyer. The current law on whether adverse possession can be claimed in your own suit.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
Academy case study · Read the explainer
Gurudwara Sahib v. Gram Panchayat Village Sirthala
Supreme Court of India · K.S. Radhakrishnan, A.K. Sikri, JJ. · Decided 16 September 2013 (reported 2014) · CA 8244/2013 · (2014) 1 SCC 669
Overruled — history onlySupreme Court · 2013
What the court held. Had held that a plaintiff cannot seek a declaration of ownership based on adverse possession, treating the plea as available only to a defendant.
Why it matters to a buyer. Listed only to show how the law changed in 2019.
Where it stands. Overruled by Ravinder Kaur Grewal v. Manjit Kaur (2019). Do not rely on it.
Sources: Judgment text · Indian Kanoon · Summary · vLex
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Karnataka Board of Wakf v. Government of India
Supreme Court of India · S. Rajendra Babu, G.P. Mathur, JJ. · Decided 16 April 2004 · CA 16899/1996 (batch) · (2004) 10 SCC 779
Good lawSupreme Court · 2004
What the court held. Adverse possession must be specifically pleaded and proved: when possession began, its nature, whether the owner knew, how long it lasted, and that it was peaceful, open, continuous, exclusive and hostile, with the intent to possess as owner. A vague plea fails.
Why it matters to a buyer. The checklist courts apply to any adverse possession claim.
Where it stands. Good law; relied on by the Supreme Court in 2024 (Vasantha v. Rajalakshmi).
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
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Hemaji Waghaji Jat v. Bhikhabhai Khengarbhai Harijan
Supreme Court of India · Harjit Singh Bedi, Dalveer Bhandari, JJ. · Decided 23 September 2008 (reported 2009) · CA 1196/2007 · (2009) 16 SCC 517; AIR 2009 SC 103
Good lawSupreme Court · 2008
What the court held. Described the law of adverse possession as harsh on true owners and recommended that the Union reconsider it. On the facts, neither title nor adverse possession was proved.
Why it matters to a buyer. Context: courts view adverse possession claims with suspicion.
Where it stands. Good law. The Law Commission’s 280th Report (2023) recommended no change to the law.
Sources: Judgment text · Indian Kanoon · Law Commission report · SCC Online
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P.T. Munichikkanna Reddy v. Revamma
Supreme Court of India · S.B. Sinha, Markandey Katju, JJ. · Decided 24 April 2007 · CA 7062/2000 · (2007) 6 SCC 59; AIR 2007 SC 1753
Good lawSupreme Court · 2007
What the court held. Long occupation alone is not adverse possession. The occupier must intend to exclude the owner, and the possession must be hostile and open so that the owner can object. The claimant carries a heavy burden; entry under sale deeds pointed to lawful rather than hostile possession.
Why it matters to a buyer. Why "we have been here twenty years" is not enough.
Where it stands. Good law. The Supreme Court said the same in Bhag Singh v. Basant Kaur (10 Sep 2026): long possession without proven hostility is not adverse possession.
Sources: Judgment text · Indian Kanoon · Judgment copy · CourtKutchehry
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State of Haryana v. Mukesh Kumar
Supreme Court of India · Dalveer Bhandari, Deepak Verma, JJ. · Decided 30 September 2011 · SLP (C) 28034/2011 (dismissed with costs) · (2011) 10 SCC 404; AIR 2012 SC 559
Good lawSupreme Court · 2011
What the court held. Dismissing the Haryana government’s petition with costs, the Court said that government departments, public undertakings and above all the police should not be permitted to take citizens’ land by claiming adverse possession. It recommended that the Union of India consider abolishing or amending the law of adverse possession.
Why it matters to a buyer. Protects owners against government departments claiming their land by long occupation. It is the Court’s statement of principle, not a statutory ban.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Summary · vLex
Academy case study · Read the explainer
State of Rajasthan v. Harphool Singh
Supreme Court of India · S. Rajendra Babu, Doraiswamy Raju, JJ. · Decided 4 May 2000 · CA 5188/1996 · (2000) 5 SCC 652
Good lawRajasthanSupreme Court · 2000
What the court held. A private person claiming adverse possession of State land must prove open, hostile and continuous possession as owner for the full thirty-year period, with clear evidence. Courts examine such claims against public land with special care. The State’s appeal was allowed.
Why it matters to a buyer. Why occupying government land in Rajasthan rarely ripens into ownership.
Where it stands. Good law; relied on in Government of Kerala v. Joseph (2023 INSC 693).
In Rajasthan. Arose in Rajasthan (Nohar).
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
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Poona Ram v. Moti Ram
Supreme Court of India · N.V. Ramana, Mohan M. Shantanagoudar, JJ. · Decided 29 January 2019 · CA 4527/2009 · (2019) 11 SCC 309; AIR 2019 SC 813
Good lawRajasthanSupreme Court · 2019
What the court held. Possession is "settled" only if it is effective, undisturbed, open and long enough that the owner has in effect accepted it; against settled possession even the owner must go to court. A casual or recent trespass is not settled possession, and the owner may remove it.
Why it matters to a buyer. Draws the line between a squatter and a settled possessor.
Where it stands. Good law.
In Rajasthan. Arose in Rajasthan (Barmer).
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
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Rame Gowda v. M. Varadappa Naidu
Supreme Court of India · R.C. Lahoti, B.N. Srikrishna, G.P. Mathur, JJ. (3 judges) · Decided 15 December 2003 (reported 2004) · (2004) 1 SCC 769; AIR 2004 SC 4609
Good lawSupreme Court · 2003
What the court held. No one, not even the true owner, may forcibly evict a trespasser in settled possession. Recovery must be through a court, and the settled possessor can get an injunction without proving title.
Why it matters to a buyer. Why taking back land by force can backfire, even for the real owner.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Judgment copy · CourtKutchehry
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Nair Service Society Ltd. v. Rev. Father K.C. Alexander
Supreme Court of India · M. Hidayatullah, S.M. Sikri, K.S. Hegde, JJ. · Decided 12 February 1968 · CA 1632/1966 · AIR 1968 SC 1165; (1968) 3 SCR 163
Good lawSupreme Court · 1968
What the court held. Possession gives a title good against everyone except the rightful owner. A dispossessed possessor can sue within twelve years on prior possession alone, and a later trespasser cannot defend himself by pointing to a third party’s better title, such as the State’s.
Why it matters to a buyer. The classic statement of possessory title.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Judgment copy · CourtKutchehry
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Right to property and the State
संपत्ति का अधिकार और राज्य
Property is no longer a fundamental right, but Article 300A still says no one may be deprived of it save by authority of law. These cases say what that protection means in practice. Read the explainer →
Kesavananda Bharati v. State of Kerala
Supreme Court of India · 13-judge Constitution Bench (S.M. Sikri CJ presiding); 7:6 · Decided 24 April 1973 · WP (C) 135/1970 · (1973) 4 SCC 225; AIR 1973 SC 1461
Good lawSupreme Court · 1973
What the court held. Parliament can amend any part of the Constitution, including fundamental rights, but cannot destroy its basic structure. The case began as a challenge to Kerala’s land reform laws.
Why it matters to a buyer. The land-reform origin of India’s best-known constitutional case.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Explainer · SCC Online
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Jilubhai Nanbhai Khachar v. State of Gujarat
Supreme Court of India · K. Ramaswamy, N. Venkatachala, JJ. · Decided 20 July 1994 (reported 1995) · 1995 Supp (1) SCC 596; AIR 1995 SC 142
Good lawSupreme Court · 1994
What the court held. Since the 44th Amendment, the right to property is a constitutional right under Article 300A, not a fundamental right and not part of the basic structure. The Court treated compensation as a matter for the legislature, not tied to market value, while saying the principles used must not be illusory.
Why it matters to a buyer. Explains why property is no longer a fundamental right. On compensation, read it with K.T. Plantation (2011).
Where it stands. Good law; cited by the Supreme Court in Bernard Francis Joseph Vaz (2 Jan 2025).
Sources: Judgment text · Indian Kanoon · Judgment copy · CourtKutchehry
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K.T. Plantation Pvt. Ltd. v. State of Karnataka
Supreme Court of India · 5-judge Constitution Bench (S.H. Kapadia CJ; K.S. Radhakrishnan J. wrote) · Decided 9 August 2011 · CA 6520/2003 · (2011) 9 SCC 1; AIR 2011 SC 3430
Good lawSupreme Court · 2011
What the court held. Under Article 300A property can be taken only by authority of law, and a public purpose is a precondition. A right to claim compensation is built into the Article, so nil or illusory compensation must be justified on grounds a court can review.
Why it matters to a buyer. The Constitution Bench statement of what Article 300A protects.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Judgment copy · CourtKutchehry
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Tukaram Kana Joshi v. M.I.D.C.
Supreme Court of India · B.S. Chauhan, J.S. Khehar, JJ. · Decided 2 November 2012 (reported 2013) · CA 7780/2012 · (2013) 1 SCC 353; AIR 2013 SC 565
Good lawSupreme Court · 2012
What the court held. Taking possession of private land without completing acquisition or paying compensation breaches Article 300A. Property is also a human right, and delay does not defeat a continuing wrong. A fresh acquisition at current market value was directed.
Why it matters to a buyer. Relief for owners whose land was taken decades ago without compensation.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Summary · vLex
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Vidya Devi v. State of Himachal Pradesh
Supreme Court of India · Indu Malhotra, Ajay Rastogi, JJ. · Decided 8 January 2020 · CA 60-61/2020 · (2020) 2 SCC 569; AIR 2020 SC 4709
Good lawSupreme Court · 2020
What the court held. When the State took a widow’s land for a road in 1967–68 without any acquisition, it breached Article 300A and her human rights. The State could not claim the land by adverse possession, and delay was no bar because the wrong was continuing. Using its powers under Articles 136 and 142, the Court ordered compensation as if the land had been formally acquired.
Why it matters to a buyer. The leading authority for owners whose land was used for a road without acquisition. The relief came under the Court’s special powers, so it is not an automatic right in every case.
Where it stands. Good law; relied on by the Supreme Court in Bernard Francis Joseph Vaz (2 Jan 2025).
Sources: Judgment text · Indian Kanoon · Commentary · IBA
Academy case study · Read the explainer
Sukh Dutt Ratra v. State of Himachal Pradesh
Supreme Court of India · S. Ravindra Bhat, P.S. Narasimha, JJ. · Decided 6 April 2022 · 2022 SCC OnLine SC 410; 2022 LiveLaw (SC) 347
Good lawSupreme Court · 2022
What the court held. Following Vidya Devi, land used for a road without acquisition was treated as deemed acquired, and the State could not use delay to avoid paying compensation.
Why it matters to a buyer. Confirms that Vidya Devi is not a one-off.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
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Hari Krishna Mandir Trust v. State of Maharashtra
Supreme Court of India · Indira Banerjee, Indu Malhotra, JJ. · Decided 7 August 2020 · CA 6156/2013 · (2020) 9 SCC 356; AIR 2020 SC 3969
Good lawSupreme Court · 2020
What the court held. However worthy its aims, the executive cannot take away a person’s property without specific authority of law. A private road wrongly shown as municipal property in a Pune town planning scheme had never been acquired or bought under the planning law, so it had not passed to the municipal corporation.
Why it matters to a buyer. A planning scheme did not quietly transfer this private land to a municipal body. The finding turned on the road never having been acquired or bought, not on a general rule for all schemes.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Report · SCC Online
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Kolkata Municipal Corporation v. Bimal Kumar Shah
Supreme Court of India · P.S. Narasimha, Aravind Kumar, JJ. · Decided 16 May 2024 · CA 6466/2024 · 2024 INSC 435; 2024 LiveLaw (SC) 382
Good lawSupreme Court · 2024
What the court held. Having a statute is not enough to satisfy Article 300A. A lawful taking must respect seven sub-rights: notice, a hearing, a reasoned decision, a public purpose, fair compensation, an efficient and timely process, and conclusion of the proceedings.
Why it matters to a buyer. A clear checklist of what the State owes an owner before taking land.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
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Property Owners Association v. State of Maharashtra
Supreme Court of India · 9 judges: majority opinion by D.Y. Chandrachud CJI for seven; B.V. Nagarathna J. partly dissenting; Sudhanshu Dhulia J. dissenting · Decided 5 November 2024 · 2024 INSC 835
Good lawSupreme Court · 2024
What the court held. Not every privately owned resource is a "material resource of the community" under Article 39(b); it depends on factors such as the resource’s nature, scarcity and effect on the community. On Article 39(b) the result was 8:1.
Why it matters to a buyer. Limits the State’s ability to treat all private property as a community resource.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Judgment summary · SC Observer
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Government of Andhra Pradesh v. Thummala Krishna Rao
Supreme Court of India · Y.V. Chandrachud CJ, A. Varadarajan, A.N. Sen, JJ. · Decided 16 March 1982 · (1982) 2 SCC 134; AIR 1982 SC 1081
Good lawSupreme Court · 1982
What the court held. Summary eviction under a land-encroachment law is for clear cases. Where someone has held land openly for long under a bona fide claim, or the government’s title is genuinely disputed, a civil court must decide.
Why it matters to a buyer. Limits eviction notices from revenue officials when title is genuinely disputed.
Where it stands. Good law; relied on by the Supreme Court in Circar Paper Mills v. District Collector, Nellore (2026 INSC 924, 25 Aug 2026).
Sources: Judgment text · Indian Kanoon · Circar Paper Mills (2026) · LiveLaw
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Waman Rao v. Union of India
Supreme Court of India · 5-judge Constitution Bench (Y.V. Chandrachud CJ, P.N. Bhagwati, V.R. Krishna Iyer, V.D. Tulzapurkar, A.P. Sen, JJ.) · Decided 13 November 1980 (reasons given 13 Nov 1980; conclusions announced 9 May 1980) · (1981) 2 SCC 362; [1981] 2 SCR 1
Good lawSupreme Court · 1980
What the court held. The Constitution Bench upheld Article 31A, which shields agrarian reform laws such as land ceiling laws, and upheld the original Article 31C to the extent Kesavananda Bharati had. It drew a line at 24 April 1973: laws put in the Ninth Schedule by amendments made before that date keep their protection; those added on or after it can be challenged if they damage the basic structure. The case arose from Maharashtra’s land ceiling law.
Why it matters to a buyer. Why land ceiling laws survived constitutional challenge.
Where it stands. Good law; I.R. Coelho (2007) applies the same 24 April 1973 line.
Sources: Judgment text · Indian Kanoon · I.R. Coelho, citing it · Indian Kanoon
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I.R. Coelho v. State of Tamil Nadu
Supreme Court of India · 9-judge Constitution Bench (Y.K. Sabharwal CJI) · Decided 11 January 2007 · (2007) 2 SCC 1; [2007] 1 SCR 706
Good lawSupreme Court · 2007
What the court held. Laws placed in the Ninth Schedule on or after 24 April 1973 do not get blanket immunity and can be struck down if they damage the basic structure. The bench answered a question referred to it and sent the individual land-law cases (estate-abolition and land-revenue laws) to a smaller bench; laws the Court had already upheld cannot be reopened on this basis.
Why it matters to a buyer. Land laws placed in the Ninth Schedule are still open to review.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Supreme Court circular listing the case
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Land acquisition and compensation
भूमि अधिग्रहण और मुआवज़ा
When the State takes land: when an old acquisition lapses, when urgency may skip the owners’ hearing, and how courts value farmland. Read the explainer →
Indore Development Authority v. Manoharlal
Supreme Court of India · 5-judge Constitution Bench (Arun Mishra J. wrote; Indira Banerjee, Vineet Saran, M.R. Shah, S. Ravindra Bhat, JJ.) · Decided 6 March 2020 · (2020) 8 SCC 129; AIR 2020 SC 1496
Good lawSupreme Court · 2020
What the court held. An acquisition begun under the 1894 Act lapses under Section 24(2) of the 2013 Act only if the State has neither taken possession nor paid compensation. Tendering compensation counts as payment, and possession can be shown by a panchnama. Pune Municipal Corporation (2014) was overruled.
Why it matters to a buyer. The rule on whether an old acquisition of your land has lapsed.
Where it stands. Good law. The Rajasthan High Court applied Section 24(2) to hold an old JDA acquisition in Jaipur tehsil lapsed (Jhutharam v. State, 27 May 2026).
Sources: Judgment text · Indian Kanoon · Later Supreme Court judgment citing it
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Pune Municipal Corporation v. Harakchand Misirimal Solanki
Supreme Court of India · R.M. Lodha, Madan B. Lokur, Kurian Joseph, JJ. · Decided 24 January 2014 · CA 877-894/2014 · (2014) 3 SCC 183; AIR 2014 SC 982
Overruled — history onlySupreme Court · 2014
What the court held. Had held that depositing compensation in the government treasury is not "payment", so old acquisitions lapsed where money was neither paid nor deposited in court.
Why it matters to a buyer. Listed only to explain why many lapse claims failed after 2020.
Where it stands. Overruled by Indore Development Authority v. Manoharlal (2020). Do not rely on it.
Sources: Judgment text · Indian Kanoon
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Radhy Shyam v. State of Uttar Pradesh
Supreme Court of India · G.S. Singhvi, A.K. Ganguly, JJ. · Decided 15 April 2011 · CA 3261/2011 · (2011) 5 SCC 553
Good lawSupreme Court · 2011
What the court held. Using urgency to skip the hearing of landowners’ objections under Section 5A is an exception that courts can scrutinise, and a general plan for industrial development did not by itself justify it. The landowners won with costs, but the State was left free to restart the acquisition from the Section 4 notification after hearing their objections.
Why it matters to a buyer. When the State can and cannot skip hearing landowners’ objections. Decided under the old 1894 Act.
Where it stands. Good law; distinguished, not overruled, in Kali Charan v. State of U.P. (2024), which upheld urgency for another project on its own facts. Under Section 40(2) of the 2013 Act, urgency powers are now limited to defence, national security and emergencies such as natural calamities.
Sources: Judgment text · Indian Kanoon · Summary
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Greater Noida Industrial Development Authority v. Devendra Kumar
Supreme Court of India · G.S. Singhvi, A.K. Ganguly, JJ. · Decided 6 July 2011 · SLP (C) 16366/2011 and connected petitions · (2011) 12 SCC 375
Good lawSupreme Court · 2011
What the court held. The Court refused to disturb the Allahabad High Court’s decision quashing an urgency acquisition in Shahberi village, because land taken for "planned industrial development" had largely been handed to builders for housing, which it called a colourable exercise of power. It imposed costs on the Authority and said flat buyers could claim refunds with interest from the builders.
Why it matters to a buyer. What happens when acquired farmland is diverted to private builders.
Where it stands. Good law.
Sources: Case record · ECOLEX · Summary · vLex
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Rajasthan Housing Board v. Shri Kishan
Supreme Court of India · B.P. Jeevan Reddy, Kuldip Singh, JJ. · Decided 27 January 1993 · (1993) 2 SCC 84; 1993 SCR (1) 269
Good lawRajasthanSupreme Court · 1993
What the court held. In a Jaipur-area acquisition under the Rajasthan Land Acquisition Act, 1953, the Court sided with the State and upheld an urgency acquisition for housing, reversing the High Court. Courts will not second-guess the government’s urgency decision where there was material on which it could fairly be reached; a few structures on a large tract do not stop the acquisition; and the government cannot withdraw once it has taken possession.
Why it matters to a buyer. A Jaipur acquisition case where the State won, useful for balance.
Where it stands. Good law. Decided under the 1953 State Act; urgency under the 2013 Act is now narrower (Section 40(2)).
In Rajasthan. Arose in Rajasthan (Jaipur).
Sources: Judgment text · Indian Kanoon · Chameli Singh (1995), citing it · Indian Kanoon
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RIICO v. Subhash Sindhi Co-operative Housing Society
Supreme Court of India · B.S. Chauhan, V. Gopala Gowda, JJ. · Decided 12 February 2013 · CA 7254/2003 and 853/2013 · (2013) 5 SCC 427; AIR 2013 SC 1226
Good lawRajasthanSupreme Court · 2013
What the court held. A purchase made after the Section 4 notification is void against the State, so the buyer cannot challenge the acquisition and can only claim compensation. An unregistered agreement to sell gives no standing, and land can be released only before possession is taken.
Why it matters to a buyer. Why buying land already under an acquisition notification is a trap.
Where it stands. Good law.
In Rajasthan. Arose in Rajasthan (Jaipur).
Sources: Judgment text · Indian Kanoon · Summary · vLex
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RIICO v. Diamond & Gem Development Corporation
Supreme Court of India · B.S. Chauhan, V. Gopala Gowda, JJ. · Decided 12 February 2013 · CA 7252-7253 and 8222-8223/2003 · (2013) 5 SCC 470; AIR 2013 SC 1241
Good lawRajasthanSupreme Court · 2013
What the court held. Contract disputes cannot be decided in writ proceedings. An allottee who accepted industrial land "as is where is" cannot later demand an access road the lease did not promise, nor take the benefit of a contract while denying its terms; RIICO’s cancellation for non-construction was upheld.
Why it matters to a buyer. Industrial plot allottees: read the lease terms before you accept.
Where it stands. Good law.
In Rajasthan. Arose in Rajasthan (Jaipur).
Sources: Judgment text · Indian Kanoon · Supreme Court copy
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Bernard Francis Joseph Vaz v. Government of Karnataka
Supreme Court of India · B.R. Gavai, K.V. Viswanathan, JJ. · Decided 2 January 2025 · SLP (C) 10338/2023 · (2025) 7 SCC 580; 2025 INSC 3
Good lawSupreme Court · 2025
What the court held. Where compensation had been delayed for about two decades, the Court used Article 142 to fix market value as on the date compensation was first assessed (2019) instead of the 2003 notification date, as an exceptional remedy for the breach of Article 300A.
Why it matters to a buyer. Long compensation delays can, exceptionally, lead a court to value land at a later date. It is an Article 142 remedy, not a general right.
Where it stands. Good law.
Sources: Supreme Court copy · Judgment text · Indian Kanoon
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Nagpur Improvement Trust v. Vithal Rao
Supreme Court of India · 7-judge Constitution Bench (S.M. Sikri CJ) · Decided 11 December 1972 (reported 1973) · (1973) 1 SCC 500; AIR 1973 SC 689
Good lawSupreme Court · 1972
What the court held. The State cannot pay one owner less than a similarly placed owner merely because it uses a different statute, authority or purpose. Denying solatium and potential value was struck down under Article 14.
Why it matters to a buyer. Equal compensation for equally placed landowners.
Where it stands. Good law. Related: in Union of India v. Tarsem Singh (4 Feb 2025) the Supreme Court refused to limit solatium and interest for 1997–2015 highway acquisitions, holding that denying them would continue unconstitutional discrimination.
Sources: Judgment text · Indian Kanoon · Report · LatestLaws
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Chimanlal Hargovinddas v. Special Land Acquisition Officer, Poona
Supreme Court of India · M.P. Thakkar, B.C. Ray, JJ. · Decided 21 July 1988 · (1988) 3 SCC 751; AIR 1988 SC 1652
Good lawSupreme Court · 1988
What the court held. The Collector’s award is only an offer. Market value is what a willing buyer would pay on the notification date, worked out from comparable sales adjusted for plus and minus factors such as size, road frontage, shape and location, with a deduction when a large tract is valued from small-plot sales.
Why it matters to a buyer. How courts value acquired farmland under the 1894 Act.
Where it stands. Good law. For acquisitions under the 2013 Act, see the note on Lal Chand below.
Sources: Judgment text · Indian Kanoon · Commentary · CaseMine
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Lal Chand v. Union of India
Supreme Court of India · R.V. Raveendran, B. Sudershan Reddy, JJ. · Decided 12 August 2009 · CA 4945/2006 (batch) · (2009) 15 SCC 769; AIR 2010 SC 170
Good lawSupreme Court · 2009
What the court held. The price of small plots in a developed colony cannot simply be applied to a large area of undeveloped farmland; a suitable deduction for the land and money development would take must be made, and how much depends on the facts. Sale deeds used as comparisons must reflect true market value.
Why it matters to a buyer. Why the price of a nearby colony plot does not set the value of your farmland.
Where it stands. Good law for 1894 Act valuations. In Madhya Pradesh Road Development Corporation v. Vincent Daniel (27 Mar 2025) the Supreme Court held the deduction method does not carry over to the 2013 Act, under which guideline rates are the starting point.
Sources: Judgment text · Indian Kanoon · Summary · vLex
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Inheritance and family property
विरासत और पारिवारिक संपत्ति
Daughters’ rights, wills, family settlements and partition: the rules that decide who else may have a claim on land a family is selling. Read the explainer →
Vineeta Sharma v. Rakesh Sharma
Supreme Court of India · Arun Mishra, S. Abdul Nazeer, M.R. Shah, JJ. (3 judges) · Decided 11 August 2020 · Diary No. 32601/2018 · (2020) 9 SCC 1; AIR 2020 SC 3717
Good lawSupreme Court · 2020
What the court held. Under Section 6 of the Hindu Succession Act as amended in 2005, a daughter is a coparcener by birth with the same rights as a son, whether or not her father was alive on 9 September 2005. Partitions made before 20 December 2004 are saved, and a plea of oral partition generally needs support from public documents.
Why it matters to a buyer. Daughters’ equal share in ancestral property, including family land.
Where it stands. Good law. Overruled Prakash v. Phulavati and partly overruled Danamma v. Amar.
Sources: Judgment text · Indian Kanoon · Supreme Court copy
Academy case study · Read the explainer
Prakash v. Phulavati
Supreme Court of India · Anil R. Dave, A.K. Goel, JJ. · Decided 16 October 2015 (reported 2016) · CA 7217/2013 · (2016) 2 SCC 36; AIR 2016 SC 769
Overruled — history onlySupreme Court · 2015
What the court held. Had held that a daughter could claim coparcenary rights only if both she and her father were alive on 9 September 2005.
Why it matters to a buyer. Listed only to explain the 2020 change.
Where it stands. Overruled by Vineeta Sharma v. Rakesh Sharma (2020). Do not rely on it.
Sources: Judgment text · Indian Kanoon
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Arunachala Gounder v. Ponnusamy
Supreme Court of India · S. Abdul Nazeer, Krishna Murari, JJ. · Decided 20 January 2022 · CA 6659/2011 · (2022) 11 SCC 520; 2022 SCC OnLine SC 72
Good lawSupreme Court · 2022
What the court held. A Hindu man’s self-acquired or partitioned property passes by inheritance, and under pre-1956 law his daughter takes it ahead of collateral relatives. Under Section 15(2), property a woman inherited from her father goes back to her father’s heirs if she dies without a will and without children.
Why it matters to a buyer. Daughters’ inheritance of a father’s self-acquired land.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
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Revanasiddappa v. Mallikarjun
Supreme Court of India · D.Y. Chandrachud CJI, J.B. Pardiwala, Manoj Misra, JJ. (3 judges) · Decided 1 September 2023 · CA 2844/2011 · (2023) 10 SCC 1
Good lawSupreme Court · 2023
What the court held. Children of void or voidable marriages are legitimate, but they are not coparceners by birth. They inherit only their parent’s property, including the parent’s notional share in the coparcenary, and cannot seek partition of the wider coparcenary. This applies to families governed by Mitakshara law.
Why it matters to a buyer. Inheritance rights of children from void marriages in family land.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Report · SCC Online
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Babu Ram v. Santokh Singh
Supreme Court of India · U.U. Lalit, M.R. Shah, JJ. · Decided 7 March 2019 · CA 2553/2019 · (2019) 14 SCC 162
Good lawSupreme Court · 2019
What the court held. The preferential right in Section 22 of the Hindu Succession Act, which gives co-heirs the first right to buy an heir’s share before it goes to an outsider, applies to agricultural land too.
Why it matters to a buyer. Family members’ first right to buy a co-heir’s share of farmland.
Where it stands. Good law; reaffirmed in Mahinder v. Puran Singh (2026 INSC 698, 14 Jul 2026), where the Supreme Court rejected a challenge to Babu Ram and declined to refer it to a larger bench.
Sources: Supreme Court copy · Mahinder (2026) · LiveLaw
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Uttam v. Saubhag Singh
Supreme Court of India · Kurian Joseph, R.F. Nariman, JJ. · Decided 2 March 2016 · CA 2360/2016 · (2016) 4 SCC 68; AIR 2016 SC 1169
Good lawSupreme Court · 2016
What the court held. Where a coparcener died after 1956 leaving a female Class I heir, his interest passed by succession through a notional partition and stopped being joint family property, so a grandson born later could not claim a coparcenary share. This applies Section 6 as it stood before 2005.
Why it matters to a buyer. Why "ancestral" land may no longer be ancestral in law.
Where it stands. Good law. Related: the Rajasthan High Court held in Devaram v. Khetaram (20 Aug 2026) that land a father inherited under Section 8 is his individual property unless a joint family estate is pleaded and shown.
Sources: Judgment text · Indian Kanoon · Commentary · ITATonline
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Kale v. Deputy Director of Consolidation
Supreme Court of India · S. Murtaza Fazal Ali, V.R. Krishna Iyer, R.S. Sarkaria, JJ. · Decided 21 January 1976 · (1976) 3 SCC 119; AIR 1976 SC 807
Good lawSupreme Court · 1976
What the court held. A bona fide family settlement binds the family and can be oral. A later memorandum that merely records it needs no registration, and those who took its benefits cannot later challenge it.
Why it matters to a buyer. How family settlements divide farmland without a registered partition deed.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Commentary · CaseMine
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Kavita Kanwar v. Pamela Mehta
Supreme Court of India · A.M. Khanwilkar, Dinesh Maheshwari, JJ. · Decided 19 May 2020 · CA 3688/2017 · (2021) 11 SCC 209; AIR 2020 SC 2614
Good lawSupreme Court · 2020
What the court held. Where suspicious circumstances surround a will, the person relying on it must remove every legitimate doubt. Probate was refused where the main beneficiary took an active part in making the will, other heirs were excluded without explanation and the attesting witnesses contradicted each other.
Why it matters to a buyer. Red flags that can sink a will over family land. The appeal came from the Delhi High Court.
Where it stands. Good law. The Supreme Court also rejected a registered will surrounded by suspicious circumstances in Ramesh Chand v. Suresh Chand (1 Sep 2025).
Sources: Judgment text · Indian Kanoon · Commentary · CaseMine
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H. Venkatachala Iyengar v. B.N. Thimmajamma
Supreme Court of India · P.B. Gajendragadkar, A.K. Sarkar, T.L. Venkatarama Aiyar, JJ. · Decided 13 November 1958 (reported 1959) · AIR 1959 SC 443; 1959 Supp (1) SCR 426
Good lawSupreme Court · 1958
What the court held. The person relying on a will must prove that the testator signed it with a sound disposing mind, understood it and made it freely. Suspicious circumstances raise that burden and must be convincingly removed.
Why it matters to a buyer. The foundational test every will dispute starts from.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Commentary · Daksha Legal
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Shub Karan Bubna v. Sita Saran Bubna
Supreme Court of India · R.V. Raveendran, B. Sudershan Reddy, JJ. · Decided 21 August 2009 · SLP (C) 17932/2009 · (2009) 9 SCC 689
Good lawSupreme Court · 2009
What the court held. A partition suit continues after the preliminary decree until a final decree divides the property by metes and bounds, and no limitation period applies to an application for a final decree. The Court urged reform to speed up partition.
Why it matters to a buyer. Why partition cases drag on, and what a preliminary decree does and does not do.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Commentary · CaseMine
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Sale agreements and specific performance
इक़रारनामा और विशिष्ट पालन
What courts do when one side of a signed agreement to sell backs out, and why a buyer who waits too long can lose the deal. Read the explainer →
K.S. Vidyanadam v. Vairavan
Supreme Court of India · B.P. Jeevan Reddy, S.B. Majmudar, JJ. · Decided 6 February 1997 · CA 7467/1996 · (1997) 3 SCC 1; AIR 1997 SC 1751
Good lawSupreme Court · 1997
What the court held. The Court refused to enforce a sale agreement for a buyer who sat on it for a long time while prices rose sharply, holding that even where time is not "of the essence", a buyer must act within a reasonable time. It spoke mainly of urban property and applied the law as it stood before 2018.
Why it matters to a buyer. Why a buyer who sits on an agreement for years may lose it.
Where it stands. Good law for the pre-2018 framework; relied on in R. Kandasamy v. T.R.K. Sarawathy (2024 INSC 884).
Before you rely on this: These rulings apply the Specific Relief Act as it stood before 1 October 2018, when enforcing a sale agreement was at the court’s discretion. The 2018 amendment says courts “shall” enforce such contracts, subject to limited exceptions. The Supreme Court’s 2022 ruling that the change applies only to later cases was recalled in November 2024 without the point being decided, so for an agreement or suit from before October 2018, check the current position with a lawyer.
Sources: Judgment text · Indian Kanoon · R. Kandasamy (2024) · Supreme Court copy
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Saradamani Kandappan v. S. Rajalakshmi
Supreme Court of India · R.V. Raveendran, K.S. Radhakrishnan, JJ. · Decided 4 July 2011 · CA 7254-7256/2002 · (2011) 12 SCC 18; AIR 2011 SC 3234
Good lawSupreme Court · 2011
What the court held. The agreement expressly made paying on the due dates essential; the buyer missed the payments, so the Court refused to enforce the sale, though she was to be refunded with interest. Judges should check strictly whether a buyer was ready and willing, and need not enforce every agreement just because the suit was filed in time. Time is still not presumed to be essential in property sales unless the agreement shows that intention.
Why it matters to a buyer. Missing the payment dates in a sale agreement can end it.
Where it stands. Good law for the pre-2018 framework; relied on in R. Kandasamy v. T.R.K. Sarawathy (2024 INSC 884).
Before you rely on this: These rulings apply the Specific Relief Act as it stood before 1 October 2018, when enforcing a sale agreement was at the court’s discretion. The 2018 amendment says courts “shall” enforce such contracts, subject to limited exceptions. The Supreme Court’s 2022 ruling that the change applies only to later cases was recalled in November 2024 without the point being decided, so for an agreement or suit from before October 2018, check the current position with a lawyer.
Sources: Judgment text · Indian Kanoon · R. Kandasamy (2024) · Supreme Court copy
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Kamal Kumar v. Premlata Joshi
Supreme Court of India · A.M. Sapre, Indu Malhotra, JJ. · Decided 7 January 2019 · CA 4453/2009 · (2019) 3 SCC 704; AIR 2019 SC 459
Good lawSupreme Court · 2019
What the court held. The Court listed the questions it asks when a buyer sues to enforce a sale agreement: is there a valid, concluded contract; has the buyer been, and is he still, ready and willing; has he actually done his part; would enforcing it be fair or cause hardship to the seller; and should another relief, such as a refund of earnest money, be given instead. The suit was decided under the law as it stood before 2018.
Why it matters to a buyer. The framework courts use when a seller backs out.
Where it stands. Good law for the pre-2018 framework.
Before you rely on this: These rulings apply the Specific Relief Act as it stood before 1 October 2018, when enforcing a sale agreement was at the court’s discretion. The 2018 amendment says courts “shall” enforce such contracts, subject to limited exceptions. The Supreme Court’s 2022 ruling that the change applies only to later cases was recalled in November 2024 without the point being decided, so for an agreement or suit from before October 2018, check the current position with a lawyer.
Sources: Judgment text · Indian Kanoon · Commentary · Mondaq
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Village commons, water bodies and ecology
गाँव की साझा ज़मीन, जल-स्रोत और पर्यावरण
Charagah, ponds, nalas, parks and land recorded as forest are held for the public. Courts have repeatedly refused to let them pass into private hands. Read the explainer →
Jagpal Singh v. State of Punjab
Supreme Court of India · Markandey Katju, Gyan Sudha Misra, JJ. · Decided 28 January 2011 · CA 1132/2011 · (2011) 11 SCC 396; AIR 2011 SC 1123
Good lawRajasthanSupreme Court · 2011
What the court held. Encroachments on Gram Sabha or Gram Panchayat common land cannot be regularised however long-standing. All States were directed to frame schemes to evict encroachers and restore common use, with narrow exceptions such as notified leases to landless labourers or SC/ST members, or schools and dispensaries already built.
Why it matters to a buyer. The national rule behind charagah and pond encroachment removals.
Where it stands. Good law; relied on by the Rajasthan High Court with Abdul Rahman in Balu Ram v. Board of Revenue (13 Feb 2026) to hold recorded johad land not open to allotment.
In Rajasthan. Applied by the Rajasthan High Court (Jagdish Prasad Meena, 2019).
Sources: Judgment text · Indian Kanoon · Summary · ELAW
Academy case study · Read the explainer
Hinch Lal Tiwari v. Kamala Devi
Supreme Court of India · S.S.M. Quadri, S.N. Phukan, JJ. · Decided 25 July 2001 · CA 4787/2001 · (2001) 6 SCC 496; AIR 2001 SC 3215
Good lawSupreme Court · 2001
What the court held. Land recorded as a village pond cannot be allotted for house building or other private use. Community resources are linked to Article 21, and the pond was ordered restored.
Why it matters to a buyer. Why land recorded as a pond is not buildable, whatever a patta says.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Case record · InforMEA
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M.I. Builders Pvt. Ltd. v. Radhey Shyam Sahu
Supreme Court of India · S.B. Majmudar, D.P. Wadhwa, JJ. · Decided 26 July 1999 · (1999) 6 SCC 464; AIR 1999 SC 2468
Good lawSupreme Court · 1999
What the court held. A municipal body holds a public park in trust; letting a builder put an underground commercial complex under it broke that trust. Most of the structure was ordered demolished and the park restored, with one block converted to public parking.
Why it matters to a buyer. The public trust doctrine applied to parks and open spaces.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Case record · ECOLEX
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T.N. Godavarman Thirumulpad v. Union of India (order of 12 Dec 1996)
Supreme Court of India · J.S. Verma, B.N. Kirpal, JJ. · Decided 12 December 1996 · WP (C) 202/1995 · (1997) 2 SCC 267; AIR 1997 SC 1228
Good lawSupreme Court · 1996
What the court held. "Forest" in the Forest (Conservation) Act, 1980 takes its ordinary dictionary meaning, and any area recorded as forest in a government record counts as forest land whoever owns it. All non-forest activity in such areas without Central Government approval had to stop.
Why it matters to a buyer. Why land recorded as forest can be unusable even if privately held.
Where it stands. Parliament narrowed the definition in 2023. While the challenge to that change is pending (Ashok Kumar Sharma v. Union of India), the Supreme Court has directed States, in orders of 19 Feb 2024 and 4 Mar 2025, to keep applying the 1996 meaning. No final judgment as of 26 Sep 2026.
Sources: Judgment text · Indian Kanoon
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Samatha v. State of Andhra Pradesh
Supreme Court of India · K. Ramaswamy, S. Saghir Ahmad, G.B. Pattanaik, JJ. (2:1; Pattanaik J. dissenting) · Decided 11 July 1997 · (1997) 8 SCC 191; AIR 1997 SC 3297
Good lawSupreme Court · 1997
What the court held. By a 2:1 majority, reading Andhra Pradesh’s Scheduled Area land-transfer law with the Fifth Schedule, government and tribal land in Scheduled Areas could not be leased to non-tribals or private companies for mining. The majority also said at least 20 per cent of net profits should be set apart as a permanent fund for water, schools, hospitals, sanitation and roads.
Why it matters to a buyer. Protection of land in Fifth Schedule areas. In Rajasthan, the State’s own tenancy law governs such land.
Where it stands. Good law. In BALCO Employees Union (2001) a later bench voiced strong doubts about the majority view but did not overrule it.
Sources: Judgment text · Indian Kanoon · Summary · ESCR-Net
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Orissa Mining Corporation v. Ministry of Environment & Forest (Niyamgiri)
Supreme Court of India · Aftab Alam, K.S. Radhakrishnan, Ranjan Gogoi, JJ. · Decided 18 April 2013 · WP (C) 180/2011 · (2013) 6 SCC 476
Good lawSupreme Court · 2013
What the court held. Under the Forest Rights Act, the local Gram Sabhas had to decide whether a proposed bauxite mine would affect forest dwellers’ community, cultural and religious rights, and the Environment Ministry could decide on forest clearance only in light of what they decided. The Gram Sabhas rejected the project and clearance was refused.
Why it matters to a buyer. The Gram Sabha’s role under the Forest Rights Act before forest land is diverted.
Where it stands. Good law.
Sources: Judgment text · Indian Kanoon · Report · Down To Earth
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Jagdish Prasad Meena v. State of Rajasthan
Rajasthan High Court (Jaipur Bench) · Mohammad Rafiq, Goverdhan Bardhar, JJ. · Decided 30 January 2019 · D.B. CWP (PIL) 10819/2018
Directions in forceRajasthanRajasthan High Court · 2019
What the court held. Directed a permanent Public Land Protection Cell in every district, headed by the Collector, to take complaints and remove encroachments on charagah, johad, talab, rivers and river beds, public ways, cremation and burial grounds and panchayat land. Following Jagpal Singh, removal is the rule and regularisation the exception.
Why it matters to a buyer. The Rajasthan route for complaints about encroached charagah and village water bodies.
Where it stands. Directions order in a continuing public interest case, not a final disposal.
Sources: Judgment text · Indian Kanoon · Related order · Indian Kanoon
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Abdul Rahman v. State of Rajasthan
Rajasthan High Court (Jodhpur) · N.N. Mathur, K.K. Acharya, JJ. · Decided 2 August 2004 · D.B. CWP 1536/2003 · 2004 (4) WLC (Raj.) 435
Good lawRajasthanRajasthan High Court · 2004
What the court held. Hearing a public interest petition about construction on recorded river and catchment land, the Court found indiscriminate use of catchment areas and directed the State to consider an expert committee’s recommendations and plan, within three months, how to restore catchment areas to their original shape. One recommendation was that land shown as rivers, nalas and drainage channels on 15 August 1947 be treated as government land.
Why it matters to a buyer. Why land in a recorded nala or catchment cannot safely be built on in Rajasthan.
Where it stands. Still relied on. Later High Court judgments describe a further 2008 decision in the same case directing removal of encroachments from catchment areas; Balu Ram v. Board of Revenue (13 Feb 2026) relied on it with Jagpal Singh.
Sources: Judgment copy · IELRC (PDF) · Keemaya Resorts (2026), citing it · Indian Kanoon
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Rajasthan: SC/ST khatedari land (Section 42)
राजस्थान: एससी/एसटी खातेदारी भूमि (धारा 42)
Section 42 of the Rajasthan Tenancy Act, 1955 restricts transfers of land held by Scheduled Caste and Scheduled Tribe khatedars. A sale in breach is void, and years of possession do not cure it. Read the explainer →
State of Rajasthan v. Aanjaney Organic Herbal Pvt. Ltd.
Supreme Court of India · K.S. Radhakrishnan, Dipak Misra, JJ. · Decided 20 September 2012 · CA 6741-6742/2012 · (2012) 10 SCC 283; AIR 2013 SC 581
Good lawRajasthanSupreme Court · 2012
What the court held. Section 42(b) of the Rajasthan Tenancy Act bars a Scheduled Caste khatedar from transferring land to a non-SC person, and a company or other juristic person is covered. The sale was void and mutation rightly refused.
Why it matters to a buyer. Buying SC khatedari land through a company does not get around Section 42.
Where it stands. Good law; followed in Rajasthan Housing Board v. New Pink City (2015).
In Rajasthan. Arose in Rajasthan.
Sources: Judgment text · Indian Kanoon · Summary · The Laws
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Rajasthan Housing Board v. New Pink City Nirman Sahkari Samiti Ltd.
Supreme Court of India · H.L. Dattu CJI, A.K. Sikri, Arun Mishra, JJ. · Decided 1 May 2015 · CA 1527-1536/2013 · (2015) 7 SCC 601; AIR 2015 SC 2126
Good lawRajasthanSupreme Court · 2015
What the court held. Agreements by Scheduled Caste khatedars to sell khatedari land to a housing society were void under Section 42, even though some members of the society were SC. When the land was acquired, only the khatedars or their heirs could claim compensation.
Why it matters to a buyer. Housing-society purchases of SC khatedari land are void, and so are the compensation claims that follow.
Where it stands. Good law.
In Rajasthan. Arose in Rajasthan.
Sources: Judgment text · Indian Kanoon · Summary · Law Intellect
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Anandi Lal v. Dalip Prajapat, Tehsildar
Rajasthan High Court (Jaipur Bench) · Avneesh Jhingan, J. · Decided 3 February 2025 · S.B. CWP 713/2005 · 2025:RJ-JP:4491; 2025 LiveLaw (Raj) 61
Good lawRajasthanRajasthan High Court · 2025
What the court held. Someone who bought land in breach of Section 42 of the Rajasthan Tenancy Act cannot later claim khatedari rights by adverse possession. Years of possession do not cure a transfer the law treats as void.
Why it matters to a buyer. Holding SC/ST land for years after a void purchase does not create rights. Indian Kanoon lists the case as Anandi Lal v. State of Rajasthan.
Where it stands. Good law; no appeal found as of 26 Sep 2026.
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
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LRs of Teja Ram v. State of Rajasthan
Rajasthan High Court (Jodhpur) · S. Ravindra Bhat CJ, Dinesh Mehta J. · Decided 19 August 2019 · D.B. Special Appeal (Writ) 1103/2017 · AIROnline 2019 RAJ 778
Stayed by the Supreme CourtRajasthanRajasthan High Court · 2019
What the court held. Held that the Section 42 bar covers a transfer by an SC/ST khatedar even to a person or body that has no caste, such as a municipal board.
Why it matters to a buyer. Shows how far the Section 42 bar may reach, pending the Supreme Court’s word.
Where it stands. The Supreme Court granted leave and stayed this judgment on 13 Jul 2020 (Municipal Board Sirohi v. Teja Ram, CA 2761-2762/2020). As far as we can find, the appeal has not been decided, so this is not settled law.
Sources: Judgment text · Indian Kanoon · Supreme Court stay order · Indian Kanoon
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Rajasthan: conversion and master plans
राजस्थान: भूमि रूपांतरण और मास्टर प्लान
Section 90-A conversion and the master plan decide what agricultural land may become. The Gulab Kothari judgments hold the plan to be binding. Read the explainer →
Bhanwar Singh v. State of Rajasthan
Rajasthan High Court (Jodhpur) · Akil Kureshi CJ, Sudesh Bansal J. · Decided 9 February 2022 · D.B. CWP 15150/2021 (with 13782/2021) · 2022 LiveLaw (Raj) 57
Good lawRajasthanRajasthan High Court · 2022
What the court held. The State may regularise agricultural land put to non-agricultural use without permission (under Section 90-B then, Section 90-A now). 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 2021 campaign circulars were upheld within these limits.
Why it matters to a buyer. What regularisation of unconverted land can and cannot fix.
Where it stands. Good law. It also noted an amendment making zonal plans optional for urban areas with under one lakh population.
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
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Gulab Kothari v. State of Rajasthan (2017)
Rajasthan High Court (Jodhpur, principal seat) · Sangeet Lodha, Arun Bhansali, JJ. · Decided 12 January 2017 · D.B. CWP (PIL) 1554/2004 · 2017 (1) WLC (Raj.) 562; 2017 (2) RLW 1178 (Raj.)
Good lawRajasthanRajasthan High Court · 2017
What the court held. Master development plans must be followed faithfully. Land marked as ecological zone, green belt or peripheral belt should not be changed, and parks, playgrounds and open spaces reserved in the plan must be preserved. Change of land use is allowed only as an exception, following the statutory procedure and in genuine public interest.
Why it matters to a buyer. The ruling behind conversion and layout refusals near Rajasthan’s cities.
Where it stands. Still applied: Vikas Modi v. State (17 Jul 2026) upheld cancellation of a patta on master-plan green belt, relying on it. The State’s appeal went to the Supreme Court, which, by the High Court’s own later account, sent the matter to a three-judge High Court bench (see 2018). Check whether any later Supreme Court appeal affects these directions before relying on them.
Sources: Judgment copy · CourtKutchehry · Supreme Court notice order, 14 Jul 2017 · Indian Kanoon
Academy case study · Read the explainer
Gulab Kothari v. State of Rajasthan (three-judge bench, 2018)
Rajasthan High Court (three-judge bench) · Pradeep Nandrajog CJ, Sangeet Lodha, Arun Bhansali, JJ. · Decided 15 December 2018 · D.B. CWP (PIL) 1554/2004 · 2019 (1) WLC (Raj.) 645
Good lawRajasthanRajasthan High Court · 2018
What the court held. Refused the State’s request to relax the 2017 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.
Why it matters to a buyer. Why conversion in master-plan areas often waits for zonal plans.
Where it stands. Qualified: a later amendment makes zonal plans optional for urban areas with under one lakh population (noted in Bhanwar Singh, 2022), so check the current rules for the specific town. The order’s operative paragraph is quoted in Bhanwar Singh.
Sources: Bhanwar Singh (2022), quoting it · Indian Kanoon · Report · Rajasthan Patrika
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Rajasthan: Sambhar, orans, Aravalli and bustard habitat
राजस्थान: सांभर, ओरण, अरावली और गोडावण
Environmental rulings that decide whether land near Sambhar Lake, oran land, Aravalli hills or bustard priority areas can be used the way a seller says. Read the explainer →
In Re: T.N. Godavarman Thirumulpad (orans and sacred groves of Rajasthan)
Supreme Court of India · B.R. Gavai, S.V.N. Bhatti, Sandeep Mehta, JJ. · Decided 18 December 2024 · I.A. 41723/2022 in WP (C) 202/1995 · 2024 INSC 997; 2024 SCC OnLine SC 3778
Directions in forceRajasthanSupreme Court · 2024
What the court held. Rajasthan’s orans, dev-vans and rundhs are to be treated as forests whatever their size. The State must map them on the ground and by satellite and consider notifying them as community reserves, under the oversight of a committee preferably headed by a retired High Court judge.
Why it matters to a buyer. Oran land near villages may be treated as forest, not buildable land.
Where it stands. As reported, the State has begun identifying and classifying these lands; we could not find a final notification. The Rajasthan High Court ordered status quo on oran land in a Jaisalmer solar project until the State decides (17 Sep 2026).
Sources: Supreme Court copy · Report · Down To Earth
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M.K. Ranjitsinh v. Union of India (Great Indian Bustard)
Supreme Court of India · 21 Mar 2024: D.Y. Chandrachud CJI, J.B. Pardiwala, Manoj Misra, JJ.; 19 Dec 2025: P.S. Narasimha, Atul S. Chandurkar, JJ. · Decided 21 March 2024 · WP (C) 838/2019 with CA 3570/2022 · 2024 INSC 280; final judgment 2025 INSC 1472
Good lawRajasthanSupreme Court · 2024
What the court held. The 2024 judgment replaced a blanket order to put power lines underground across bustard habitat with an expert-committee approach, and recognised a right against the adverse effects of climate change. The final judgment of 19 Dec 2025 approved revised priority areas in Rajasthan and Gujarat: inside them, new wind turbines and solar parks above 2 MW are barred, and new overhead lines must use the approved power corridors (lines of 11 kV and below excepted).
Why it matters to a buyer. Solar, wind and power-line limits in bustard priority areas decide land use in western Rajasthan.
Where it stands. Decided and disposed of on 19 Dec 2025. The judgment gives the Rajasthan priority area as 14,013 sq km.
In Rajasthan. Rajasthan and Gujarat.
Sources: Final judgment, 19 Dec 2025 · Supreme Court copy · 2024 judgment · Supreme Court copy · Report · Down To Earth
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In Re: Definition of Aravalli Hills and Ranges
Supreme Court of India · 20 Nov 2025: B.R. Gavai CJI, K. Vinod Chandran, N.V. Anjaria, JJ.; 29 Dec 2025: Surya Kant CJI, J.K. Maheshwari, A.G. Masih, JJ. · Decided 20 November 2025 · I.A. 105701/2024 in WP (C) 202/1995; SMWP (C) 10/2025 · 2025 INSC 1338
On holdRajasthanSupreme Court · 2025
What the court held. On 20 Nov 2025 the Court accepted a working definition of an Aravalli hill (100 metres or more above local relief) and range (two or more such hills within 500 metres) and barred new mining leases pending a sustainable mining plan. On 29 Dec 2025 it put that judgment in abeyance and ordered an expert committee to re-examine the definition.
Why it matters to a buyer. Which Aravalli land counts as protected hill is still undecided.
Where it stands. In abeyance. As reported, the Court refused the committee more time on 7 Sep 2026, fixed 30 Nov 2026 as the deadline for its report and listed the case for 2 Dec 2026. Re-check before relying on any definition.
In Rajasthan. Rajasthan (Aravalli districts).
Sources: Judgment of 20 Nov 2025 · Supreme Court copy · Report, 7 Sep 2026 · LiveLaw · Report, 29 Dec 2025 · Down To Earth
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Sambhar Salt Ltd. v. Ministry of Environment, Forest and Climate Change
National Green Tribunal, Central Zone (Bhopal) · Sudhir Agarwal (Judicial Member), Dr Afroz Ahmad (Expert Member) · Decided 9 November 2023 · O.A. 94/2022 (CZ)
Directions in forceRajasthanNational Green Tribunal · 2023
What the court held. Directed scientific demarcation of the Sambhar Lake wetland with core and buffer areas, removal of illegal borewells and encroachments, a finalised wetland management plan and treatment of sewage before it reaches the lake.
Why it matters to a buyer. Land near Sambhar Lake may fall inside the wetland or its zone of influence.
Where it stands. A 2024 execution application was closed with directions to comply on time. As far as we can find, the Sambhar wetland boundary has been published only in draft (December 2023) and has not been finally notified.
In Rajasthan. Sambhar, in AgriZameen’s focus belt.
Sources: Judgment text · Indian Kanoon · Execution order · Indian Kanoon
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News item in Hindustan Times titled “Sambhar’s ecology among worst: Report”
National Green Tribunal, Principal Bench · Adarsh Kumar Goel (Chairperson), Sheo Kumar Singh (Judicial Member), Dr Nagin Nanda (Expert Member) · Decided 18 March 2021 · O.A. 1020/2019
Case closedRajasthanNational Green Tribunal · 2021
What the court held. After the 2019 bird deaths, the Tribunal pressed for closure of about 500 illegal borewells, an immediate stop to sewage reaching the lake, prosecution on the polluter-pays principle and a comprehensive environment management plan, and closed the case with directions to keep implementing them.
Why it matters to a buyer. The enforcement history behind borewell and sewage rules around Sambhar.
Where it stands. Disposed of on 18 Mar 2021. Later follow-up came through other NGT cases.
In Rajasthan. Sambhar, in AgriZameen’s focus belt.
Sources: Judgment text · Indian Kanoon · Earlier order · Indian Kanoon
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Dinesh Kumawat v. Union of India (100 MW solar project near Sambhar Lake)
Rajasthan High Court (Jaipur Bench) · Sanjeev Prakash Sharma ACJ, Sanjeet Purohit J. · Decided 28 April 2026 · D.B. CWP 19341/2025 · 2026:RJ-JP:17138-DB; 2026 LiveLaw (Raj) 170
Interim orderRajasthanRajasthan High Court · 2026
What the court held. Lifted its stay and let a 100 MW solar project near Sambhar Lake proceed, accepting that the site was not notified wetland, on conditions: panels at least 1.5 metres high, three trees planted for each one felled, and no blocking of water flowing onto the land.
Why it matters to a buyer. How the court is balancing solar projects against Sambhar’s bird habitat, case by case.
Where it stands. Interim order, corrected on 14 May 2026. A parallel petition over the same project was disposed of on 15 Jul 2026 on the same conditions; the main petitions in this case appeared pending when last reported.
In Rajasthan. Sambhar, in AgriZameen’s focus belt.
Sources: Judgment text · Indian Kanoon · Report · LiveLaw
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Benami property
बेनामी संपत्ति
Where benami law stands after the Supreme Court recalled its own 2022 ruling.
Union of India v. Ganpati Dealcom Pvt. Ltd.
Supreme Court of India · N.V. Ramana CJI, Krishna Murari, Hima Kohli, JJ. · Decided 23 August 2022 · CA 5783/2022 · (2022) 447 ITR 108 (SC)
Recalled — being reheardSupreme Court · 2022
What the court held. Had held that the 2016 benami amendments could not reach transactions made before 25 Oct 2016, and struck down Sections 3(2) and 5 of the 1988 Act.
Why it matters to a buyer. Listed to explain where benami law stands after the recall.
Where it stands. Recalled on 18 Oct 2024 (2024 INSC 799); the appeal is to be heard again and, as far as we can find, has not been decided. As reported, a two-judge bench held in May 2026 (Manjula v. D.A. Srinivas) that the amended Act’s civil provisions such as confiscation can apply to older transactions, while criminal penalties cannot. The position is still developing.
Sources: Judgment text · Indian Kanoon · Recall order · Indian Kanoon · Manjula (May 2026) · LiveLaw
How these entries were checked
Every entry was checked on 26 September 2026 against a copy of the judgment or order, or a report of it by a legal publisher, that we opened; the sources are linked under each case. Where a later ruling changed or qualified a case, the entry says so. Summaries are ours, in plain language, and none has been reviewed by a practising advocate. A summary compresses and can be wrong, and the law moves: read the judgment itself and take advice from a licensed advocate before you rely on any of this. To report an error, message +91 92502 13833 on WhatsApp or write to support@agrizameen.com, naming the case.
FAQ · अक्सर पूछे सवाल
Does a GPA or an agreement to sell make me the owner of land?
No. In Suraj Lamp (2011) the Supreme Court held that a sale agreement, a general power of attorney and a will, alone or together, do not transfer ownership; only a registered sale deed does. In Shakeel Ahmed (2023) it held this is the existing law, not only for deals after 2011.
Does my name in the jamabandi prove that I own the land?
No. The Supreme Court has held many times, from Sawarni (1996) to Karam Singh (2025), that a mutation neither creates nor extinguishes title; it records who pays land revenue. Ownership disputes are for a civil court.
Can someone become the owner of land by occupying it for twelve years?
Only if he proves adverse possession strictly: open, continuous, exclusive and hostile possession, with intent to hold as owner, for the full limitation period. Long occupation alone is not enough, and a claim against government land needs thirty years and clear evidence (Harphool Singh, 2000).
Can a non-SC buyer purchase agricultural land from a Scheduled Caste khatedar in Rajasthan?
Section 42 of the Rajasthan Tenancy Act bars such a transfer. The Supreme Court held a sale to a company void in Aanjaney Organic Herbal (2012), and the Rajasthan High Court held in Anandi Lal (2025) that years of possession after such a purchase do not create khatedari rights.
Do daughters have a share in ancestral property?
Under Section 6 of the Hindu Succession Act, as the Supreme Court read it in Vineeta Sharma (2020), a daughter is a coparcener by birth with the same rights as a son, whether or not her father was alive on 9 September 2005. Partitions made before 20 December 2004 are saved.
Is this page legal advice?
No. AgriZameen is an independent private platform, not a law firm and not a government body. These are plain-language summaries for learning; read the judgment and take advice from a licensed advocate before acting on any of them.
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.