Ramesh Pal Mehta vs Financial Commissioner & Ors on 10 February, 2026

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Delhi High Court - Orders

Ramesh Pal Mehta vs Financial Commissioner & Ors on 10 February, 2026

1. The Petitioner was arrayed as Respondent No. 2 before the Financial Commissioner in a revision petition under Section 42 of the East Punjab Holdings (Prevention of Fragmentation) Act, 1948 filed by Prashant Mudgal and Virender Rana. The said petition assailed orders dated 26th September, 2022 and 23rd February, 2024 passed by the Consolidation Officer/Tehsildar, Alipur, Delhi. In those proceedings, the Petitioner questioned the locus standi of the revision petitioners in those proceedings.

2. The revision petition was disposed of by the impugned order dated 24th September, 2025, holding as under:

"13. The above rulings do not provide for continued applicability of the Delhi Land Reforms Act, 1954 by the revenue courts. After the declaration of the land/village i.e. Bakoli as Low Density Residential Area vide W.P.(C) 1911/2026 Page 1 of 4 This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/02/2026 at 21:32:52 notification dated 18.06.2013, the definition of the land which is derived from the Delhi Land Reforms Act is non-est once the Land Reforms Act goes In terms of the above judgment.

14. Averting to the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948, the purpose of this Consolidation Act as mentioned in Its preamble is "An Act to provide for the compulsory consolidation of agricultural holdings and for preventing the fragmentation of agricultural holdings in the State of Punjab and for the assignment or reservation of land for common purpose of the village . The entire outcome of the process of consolidation to achieve the purpose staled in the preamble of consolidation is to prepare a new record of rights in accordance with the Land Revenue Act as per Section 22 of the Consolidation Act.

15. The basic purpose of the Consolidation Act therefore is to prevent fragmentation of land and to render agricultural activity to remain viable. The mother document on which the entire consolidation is based on, is the 'record of rights'. The record of rights in the Consolidation Act is as defined in Sections 6 and 22 of the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948 and takes Its definition from the Punjab Land Revenue Act. In the case of GNCTD, the same Punjab Land Revenue Act, 1887 has been extended to Delhi through the aegis of Delhi Land Revenue Act, 1954.

16. As already explained in the foregoing, once the Delhi Land Reforms Act and the Delhi Land Revenue Act cease to exist, post notification under Section 11 of Delhi Development Act, 1957 the consolidation proceedings, even if started before or after the said notification cannot continue. This is because 'record of rights' of land as legally defined and sanctified by the-Delhi Land Reforms Act and the Delhi Land Revenue Act cannot continue after the notification and the said Revenue acts ceasing to exist except for reference and record purposes. Therefore, once the applicability of Delhi Land Reforms Act, 1954 ceases as per the judgment of the Hon'ble High Court in WP(C) No.3502/2022 titled Rajeev Shah (Deceased) through LR Gayatri Shah Vs. Government of NCT of Delhi & Ors., the revenue laws and as a logical extension as explained elsewhere above, the consolidation law cannot continue to remain valid. The remedies will lie elsewhere.

17. In the light of all the foregoing, to review the matter where the village already stood declared as Low Density Residential Area In 2013 would involve entering into an area where the revenue courts have no jurisdiction to enter. Therefore, in terms of the above judgments of the Hon'ble High Court the revenue courts cease to have jurisdiction qua the lands covered under the Low Density Residential Area notification dated 18.06.2013. Accordingly, this Court also does not have any Jurisdiction to adjudicate the proceedings under the dispute. Further, needless to say that any orders passed by the Consolidation Officer passed after the village W.P.(C) 1911/2026 Page 2 of 4 This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/02/2026 at 21:32:52 was declared Low Density Residential Area under the Delhi Development Act cannot be Implemented for the reason explained elsewhere above. Accordingly, the proceedings conducted by the Consolidation Officer in case No.l05/19/CO/Alipur/2022 and cas No.The/AP/Misc.2023/ are liable to be declared non-est and are declare / non-est in terms of the above judgements of Hon'ble High Court Needless to say that impugned orders dated 26.09.2022 and 23.02.2024 passed by the Consolidation Officer are also liable to be set aside and are set aside being passed after 18.06.2013 declaring the village Bakoli as LDRA as the revenue courts ceased to have jurisdiction in terms of the above judgments. Accordingly, the revision petition bearing No.133/2024 titled Prashant Mudgal & Anr. Vs. C.O./Tehsildar (Alipur) & Ors. is disposed of. No order as to costs.

18. Further, seeing the peculiar circumstances of the case, it would not be fair to deprive the parties from seeking remedy as per law. Accordingly, protection is provided to all the parties for the next sixty days to enable them to approach the appropriate forum of law for redressal of their grievances, if any. During this period, no third party interest shall be created by any party in the impugned land.

19. Pronounced in the open Court on 24th September, 2025."

3. The Petitioner is aggrieved by the findings in paragraph 17 of the impugned order, which prejudice his rights.

4. After addressing certain submissions, counsel for the Petitioner seeks permission to withdraw the present petition and submits that the Petitioner shall avail appropriate remedies before the competent Civil Court.

5. Counsel, however, makes a limited request that the protection granted to all the parties under paragraph 18 of the impugned order, which stood expired upon completion of sixty days, be extended for a short duration to enable the Petitioner to approach the appropriate forum.

6. In view of the above, and without examining the merits of the controversy, it is directed that the protection granted under the impugned order shall stand extended for a further period of 30 days from today.

7. The Court has not commented on the merits of the claims urged in the present petition and all rights and contentions of the parties are left open.

This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/02/2026 at 21:32:52

8. Dismissed as withdrawn along with pending applications.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/02/2026 at 21:32:52

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Delhi High Court - Orders