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Supreme Court of India 2024-05-01 allowed

RAM BALAK SINGH vs STATE OF BIHAR AND ANR

Bench: 2 — Pankaj Mithal, Prasanna Bhalachandra Varale

In Brief

A farmer (Ram Balak Singh) inherited 0.32 decimal of land through adoption from his predecessor, who held it via a lease from an ex-landlord. During consolidation proceedings, the Consolidation Officer recognized his title in 1979. Later, the State claimed the land as pond land, prompting the farmer to sue for a declaration of his title. The High Court reversed his trial-court victory. The Supreme Court held that such a declaration suit is not barred by Section 37 of the Consolidation Act (which bars suits to overturn consolidation orders). Section 37 applies only to suits challenging consolidation decisions, not suits merely recognizing rights already granted. Once the Consolidation Officer's order became final, it could not be ignored by the civil court. The Court restored the trial judgment and decreed the suit in favor of the farmer.

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Land Law Revenue and Consolidation Jurisdiction of Civil Courts Statutory Bar to Jurisdiction Constitutional Law

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