# Meena Devi v. State of U.P. & Ors

- **Citation:** (2025) 12 ILRA 1000
- **Court:** High Court of Judicature at Allahabad
- **Decided:** 2025-12-18
- **Case number:** Writ - C No. 35470 of 2025
- **Bench:** Dr. Yogendra Kumar Srivastava
- **Source:** https://unisonlegal.in/judgment/allahabad-high-court/meena-devi-v-state-of-u-p-ors-54819
- **Pages:** 19

## Text

_Characters 0–39,938 of 58,358. This is a partial read: ask again with offset=39938 for what follows._

1000 INDIAN LAW REPORTS ALLAHABAD SERIES
their main source of livelihood. In the facts
of the present case, the land stands
recorded in the name of the deceased?s
grandfather in the Khatauni, and there is no
material on record to show that the
deceased, his father, or his wife had any
other source of income. The family was
dependent upon farming for its survival,
particularly in view of the submission made
by the petitioner in the rejoinder that the
same land was mortgaged with the Bank of
India by the deceased at the time of
purchasing a tractor in the year 2011. This
fact ought to have been properly examined
by the authorities instead of rejecting the
petitioner?s claim in a casual manner.

22.
In
view
of
the
above
discussion, this Court is of the considered
view that the rejection of the petitioner's
claim is based on an unduly drawn narrow
interpretation of the scheme and merely
based on assumptions not supported by
proper enquiry, and therefore, the writ
petition deserves to be allowed and is
hereby allowed. The impugned order dated
25.08.2021 passed by the respondent no. 2,
District Magistrate, Kannauj, rejecting the
petitioner?s
claim
under
the
"Mukhyamantri Krishak Durghatna Kalyan
Yojana"and the information order dated
31.07.2021 issued by respondent no. 3 are
hereby quashed. The matter is remanded to
the
District
Magistrate,
Kannauj,
to
reconsider the petitioner?s claim afresh in
accordance with law and in the light of the
observations
made
hereinabove,
after
affording an opportunity of hearing to the
petitioner and after conducting a proper
enquiry, if required. The said exercise shall
be completed expeditiously, preferably
within a period of eight weeks from the
date of production of a certified copy of
this order. No order as to costs.
----------
(2025) 12 ILRA 1000
ORIGINAL JURISDICTION
CIVIL SIDE
DATED: ALLAHABAD 18.12.2025

BEFORE

THE HON'BLE DR. YOGENDRA KUMAR
SRIVASTAVA, J.

Writ - C No. 35470 of 2025
Alongwith other cases

Meena Devi ...Petitioner
Versus
State of U.P. & Ors. ...Respondents

Issue for Consideration
The matter pertains to systematic inaction and
non-execution of final demarcation orders
passed under Section 24 of U.P. revenue
Code,2006.

Headnotes
Constitution of India,1950-Article 226U.P. Revenue Code,2006-Section 24 & U.P.
Revenue Code Rules, 2016-Rule 22-The
SDO's power under section 24 is not
limited to mere application, it includes the
mandatory authority to restore possession
and
use
necessary
force
to
affix
boundaries-The mere filing of an appeal
does not operate as an automatic stay-In
the absence of an express interim order
from
the
Commissioner,
the
SDO's
demarcation order remains operative and
must
be
executed-If
resistance
is
apprehended, the SDO has a mandatory
duty to issue a written requisition to the
Station House Officer for Police force
under Rule 22(14)-Lack of police force is
not a valid pretext for deferring the
execution of a judicial order-Pendency of
map correction proceedings does not ipso
facto suspend the execution of section 24
order-Writ petition allowed.(Para 18 to
47) (E-6)

Held
The court held that section 24 of the U.P.
Revenue Code,2006 vests the SDO with
statutory quasi-judicial powers for summary
12 All. Meena Devi Vs. State of U.P. & Ors.
1001
settlement of boundary disputes coupled with
mandatory
enforcement
authority
for
demarcation and possession restoration. The
respondents are directed to execute all subject
orders in the instant batch of writ petition,
within four weeks from the date of order.

Case law Cited
Writ-C No. 35470 of 2025: Meena Devi Vs State
of U.P. & Ors, Writ-C No 35324 of 2025 :
Ramayan Vs State of U.P., Writ-C No. 39356 of
2025 : Anand Kumar & Ors Vs State of U.P.,
Writ-C No. 39643 of 2025 : Parasnath Vs State
of U.P.,Writ-C No. 40027 of 2025: Kishan Kumar
Vs State of U.P.,Writ-C No. 40164 of 2025:
Ramnaresh Dubey Vs State of U.P.,Writ-C No.
40165 of 2025 : Vinod Kumar Gupta Vs State of
U.P.,Writ-C NO. 35626 of 2025 Smt. Sirjawati Vs
State of U.P.-referred to.
List of Acts
U.P. Revenue Code,2006, U.P. Revenue Code
Rules 2016.

List of Keywords
Demarcation (Patthar Nasab), Summary Inquiry,
Geo-tagging/RCCMS
portal,
Wrongful
disposession, Quasi-judicial Enforcement.

Case Arising from
Civil Jurisdiction-WRIT-C No. - 35470 of 2025

Meena Devi Vs. State of U.P. & 5 Ors

From the Judgment and Order dated 18.12.2025
of the High Court of Judicature at Allahabad.

Appearances for Parties
Adv. for Petitioner:-
Rohit Pandey
Adv. for Respondent:-
 Azad Rai, C.S.C

(Delivered by Hon'ble Dr. Yogendra
Kumar Srivastava, J.)

Heard S/Sri Rohit Pandey, Sandeep
Kumar Singh, holding brief of Digamber
Dwivedi,
Munna
Tiwari
along
with
Sandeep Kumar Singh, Dharamdas, Vijay
Bahadur Yadav, Anoop Kumar Sharma,
Anurag Shukla along with Shubham
Dwivedi, Raj Kumar Shukla and Arvind
Kumar Srivastava, learned counsel for the
petitioners and Sri Manish Goyal, learned
Additional Advocate General, appearing
along with Sri J N Maurya, learned Chief
Standing Counsel, Sri Abhishek Shukla,
learned Additional Chief Standing Counsel
and Sri Ravi Anand Agarwal, learned
counsel for the State-respondents.

2. The present batch of writ petitions
raises a common grievance pertaining to
non-execution
of
demarcation
orders
passed under Section 24 of the Uttar
Pradesh
Revenue
Code,
20061,
notwithstanding the fact that such orders
have attained finality after due inquiry,
submission of reports, and issuance of
notices to the concerned parties.

3. The lead matter, being Writ-C
No. 35470 of 2025 (Meena Devi v. State of
Uttar Pradesh and others), typifies the
nature of the controversy involved in the
present set of petitions.

Factual Matrix

4. The factual background of the
cases and the contentions raised on behalf
of the petitioners, as reflected from the
pleadings, are being set out hereinbelow:

 Writ-C No.35470 of 2025 :
Meena Devi vs. State of Uttar Pradesh &
Others

4.1
Petitioner
is
a
recorded
bhumidhar with transferable rights of land
bearing Gata No.606, ad measuring 0.0240
hectare, situate in Village Ustapur Naika,
Jhunsi, District Prayagraj. The petitioners
title and possession over the said land stand
1002 INDIAN LAW REPORTS ALLAHABAD SERIES
duly recorded in the khatauni of fasli years
1429-1434, evidencing her lawful rights.

4.2 Over a period of time, the
boundaries of the aforesaid plot became
damaged
and
indistinct,
resulting
in
recurring disputes between the petitioner
and adjoining land cultivators regarding the
exact boundary line.

4.3
In
order
to
resolve
the
boundary dispute lawfully, the petitioner
along
with
other
co-tenure
holders
instituted proceedings under Section 24 of
the Code, 2006 for demarcation of
boundaries
before
the
Sub-Divisional
Magistrate, Phoolpur, District Prayagraj.
The case was registered as Case No. 191 of
2024
(Computerized
No.
T202402030200191) titled Meena Devi
and others vs. Gram Sabha and others.

4.4 During the said proceedings,
the Sub-Divisional Magistrate called for a
report from the Revenue Inspector, who
conducted a spot inspection in the presence
of all concerned parties and submitted a
demarcation report along with a map dated
28.11.2022.

4.5 On the basis of the said report,
notices were issued to all concerned parties
inviting
objections.
Despite
due
opportunity, no objections were filed by
any party, and all stakeholders were aware
of the demarcation proceedings.

4.6 After considering the material
on record, the Sub-Divisional Magistrate,
Phoolpur, allowed the application vide
order dated 02.01.2024, confirming the
demarcation
report
and
map
dated
28.11.2022, and directed the Tehsildar,
Phoolpur, to execute the demarcation by
installing permanent boundary stones.
4.7 In compliance of the said order,
the Revenue Inspector issued notice dated
12.10.2024, informing all concerned parties
that demarcation of Gata No.606 would be
carried out on 19.10.2024, and requiring
their presence for effective execution.

4.8 Thereafter, the petitioner was
repeatedly
called
on
several
dates,
namely
13.10.2024,
14.10.2024,
16.10.2024, 03.11.2024 and 05.11.2024,
for demarcation proceedings. However,
on each occasion, the demarcation work
was deferred on the pretext of nonavailability of police force, despite the
existence of a valid and subsisting
judicial order.

4.9
Due
to
persistent
nonexecution of the demarcation order, the
petitioner submitted an application dated
02.12.2024 to the concerned authorities
through
registered
post,
requesting
immediate compliance of the order dated
02.01.2024. Despite receipt of the said
application, the respondents have failed
to take any action.

4.10 Non-demarcation of her land
has caused the petitioner grave hardship
and irreparable loss, as the boundary
dispute with adjoining landholders remains
unresolved.

Writ-C No.35324 of 2025 :
Ramayan vs. State of Uttar Pradesh

5. Petitioner, Ramayan, filed a
demarcation case under Section 24 of the
Code, 2006 before the Sub-Divisional
Magistrate, Rudrapur, District Deoria in
respect of Gata Nos.174, 175, 178, 179,
181, 184 and 185. The said demarcation
case
was
decided
by
order
dated
06.02.2023.
12 All. Meena Devi Vs. State of U.P. & Ors.
1003
5.1 During the pendency of the said
proceedings, respondent nos. 4 to 9
instituted a separate case for correction of
map under Section 30 of the Code, 2006
before the Additional District Magistrate
(Finance & Revenue), Deoria, which is
pending.

5.2 While passing the order dated
06.02.2023, the S.D.M. directed the parties
to maintain status-quo only till the expiry
of the limitation period for filing an appeal,
noting the pendency of the proceedings
under Section 30.

5.3 Despite the expiry of the
limitation period, the revenue authorities
have failed to comply with the demarcation
order on the pretext of pendency of the
proceedings (Lekhpal giving a report
stating that since a case under section 30 is
pending, therefore order of Section 24
cannot
be
complied).
Repeated
representations, including after dismissal of
the appeal, have remained unattended.

5.4
Petitioner
submitted
a
representation dated 22-09-2025 before
respondent no.2, to comply with order
dated 06-02-2023, but no action has been
taken.

5.5 The inaction and refusal of the
respondents to implement a final and
binding order is arbitrary, illegal and
unsustainable in the eyes of law, giving rise
to the present writ petition seeking
enforcement of the order dated 06.02.2023.

Writ-C No. 38105 of 2025 :
Satendra Mani v. State of Uttar Pradesh

6. Petitioner filed a case for
demarcation of his land bearing Arazi No.
898, area 3.376 hectare, situated at village
Sabaya
Ray,
Tehsil
Kasya,
District
Kushinagar. The said case was instituted
before the Sub Divisional Magistrate
(Judicial),
Tehsil
Kasya,
District
Kushinagar, respondent no. 2, and was
registered as Case No. 9568 of 2024,
Computer Case No. T202405440409568
(Satendra Mani Vs. Chairman, Nagar
Palika Parishad, Kushinagar).

6.1 Pursuant thereto, respondent
no. 3 passed an order dated 01.04.2025
directing demarcation of the petitioners
land. However, despite lapse of more than
six months from the date of the said order,
the demarcation has not been carried out by
the
concerned
authorities.
Petitioner
repeatedly
moved
applications
before
respondent no.2, requesting compliance of
the order dated 01.04.2025, but no action
was taken.

Writ-C No 39356 of 2025 :
Anand Kumar & Others v. State of
Uttar Pradesh

7. Petitioners instituted a case for
demarcation under Section 24 of the Code,
2006, which was registered as Case No.
4673 of 2023, Computerized Case No.
T202305440304673 (Anand Kumar and
others Vs. Ramashasnkar and others). The
Revenue Inspector submitted his report,
which was duly examined by the SubDivisional Officer2 (Magistrate), Tehsil
Tamkuhiraj, District Kushinagar, and found
to be correct.

7.1 Accordingly, vide order dated
28.06.2023, the SDO directed affixation of
boundary
stones
over
Gata
Nos.
1691/4374/0.099 and 1696/0.024 situate in
Village
Barwa
Rajapakad,
Tehsil
Tamkuhiraj, District Kushinagar. Despite
repeated
approaches
made
by
the
1004 INDIAN LAW REPORTS ALLAHABAD SERIES
petitioners for compliance of the said order,
the authorities have failed to implement the
same. Hence, the writ petition has been
filed.

Writ-C No.39643 of 2025 :
Parasnath vs. State of Uttar Pradesh

8. Petitioner, Paras Nath, filed a
case under Section 24 of the Code, 2006 for
measurement and demarcation of Gata
Nos.234 (0.229 hectare) and 285 (0.253
hectare)
situate
in
village
Chaukiya,
Pargana Mahul, Tehsil Phoolpur, District
Azamgarh, which was registered as Case
No. 1973 of 2025 (Computerized Case No.
T202515060301973), Paras Nath vs. Om
Prakash and others, before the UpZiladhikari, Tehsil Phoolpur. In the said
proceedings, a report was called for from
the revenue authorities, pursuant to which
the Revenue Inspector submitted a report
dated 16.07.2024 after spot inspection and
measurement, along with the field book,
which
was
forwarded
through
the
Tehsildar, Phoolpur. Though objections
were filed by the private respondents
alleging lack of notice and inspection, the
competent authority, after considering the
objections, the revenue report and relevant
records, approved the report vide order
dated 12.03.2025.

8.1 Despite the final order dated
12.03.2025 approving the demarcation and
entitling the petitioner to possession over
the aforesaid land, the petitioner has not
been put in possession till date. The private
respondents
are
obstructing
the
implementation of the order and are
threatening the petitioner and the local
police
authorities
are
not
extending
cooperation.
The
petitioner
made
representations
dated
14.08.2025
and
08.09.2025
before
the
Sub-Divisional
Magistrate seeking enforcement of the
order, but no action has been taken. The
continued inaction of the respondents in
giving effect to a lawful and final order is
arbitrary and illegal, leaving the petitioner
with no alternative remedy, and hence the
present writ petition has been filed seeking
issuance of a writ of mandamus for
compliance of the order dated 12.03.2025
and delivery of possession of the disputed
land.

Writ-C No.40027 of 2025 :
Kishan Kumar v. State of Uttar Pradesh

9. Petitioner filed Case No. 4747 of
2021,
Computerized
Case
No.
T202102420304747 under Section 24 of
the Code, 2006 on 04.06.2021, seeking
demarcation.
The
Revenue
Inspector
conducted measurement in presence of
concerned parties and submitted a report
dated 07.07.2021, which was forwarded by
the Tehsildar, Tehsil Manjhanpur.

9.1 After service of notice and
absence of objections, respondent no. 2
confirmed the report vide order dated
19.05.2022 and directed affixation of
boundary stones. In pursuance thereof,
notices dated 06.09.2025, 08.09.2025, and
17.09.2025 were issued fixing dates for
compliance, but neither the Revenue
Inspector reached the spot nor were stones
fixed.
Repeated
approaches
by
the
petitioner to the Revenue Inspector and
respondent no. 2 yielded no result. Hence,
the present writ petition has been filed.

Writ-C No.40164 of 2025 :
Ramnaresh Dubey v. State of Uttar
Pradesh

10. Petitioner is a co-sharer of Gata
No. 684, area 0.434 hectare, situated at
12 All. Meena Devi Vs. State of U.P. & Ors.
1005
Village Tiwaripur (Kasivar), Tehsil Sadar,
District Mirzapur. Along with other cosharers, the petitioner filed Case No. 10256
of
2024,
Computerized
Case
No.
T202416530110256 under Section 24 of
the Code, 2006 seeking measurement and
Patthargaddi.

10.1 Pursuant to directions dated
26.07.2024,
the
Revenue
Inspector
submitted a measurement report and map.
Vide order dated 30.11.2024, Patthargaddi
was directed. Subsequently, the Revenue
Inspector reported on 13.01.2025 that
police force was required. Correspondence
ensued
between
the
Sub
Divisional
Magistrate
and
District
Magistrate,
culminating in a report dated 21.03.2025,
which indicated that demarcation and
Patthargaddi cannot be carried out without
sufficient police force. Hence, the present
writ petition has been filed.

Writ-C No.40165 of 2025 : Vinod
Kumar Gupta vs. State of Uttar Pradesh

11.
Petitioners
father
was
recorded in the Khatauni of Gata No. 833,
area 0.0220 hectare. Upon his death on
26.04.2021, the petitioner and his brother
were mutated and remained in possession.
Subsequently, the petitioners brother filed
an application dated 24.12.2024 under
Section 24 of the U.P. Revenue Code, 2006
for demarcation after depositing challan on
23.12.2024.

11.1 Inspection was conducted and
reports were submitted between 25.04.2025
and 23.07.2025. Despite orders restraining
illegal construction and a final demarcation
order dated 30.07.2025, the authorities
failed to enforce the same, resulting in
illegal construction by respondents. Even
after application dated 06.11.2025, no
action was taken, compelling the petitioner
to file the present writ petition.

Writ-C No.35626 of 2025 : Smt.
Sirjawati v. State of Uttar Pradesh

12. Petitioner, a Bhumidhar with
transferable rights over Plot No. 1411, area
0.4950 hectare, filed Case No. 6797 of
2025 under Section 24 of the Code, 2006
for permanent demarcation. Upon calling
for
reports,
the
Revenue
Inspector
submitted the demarcation report and field
book, which was approved by respondent
no. 4.

12.1 By order dated 28.02.2025,
respondent no. 3 directed permanent
demarcation within 15 days. Despite lapse
of more than eight months, the said order
has not been complied on the spot, causing
irreparable loss to the petitioner. Hence, the
present writ petition has been filed.

Common
Grievance
of
the
Petitioners

13. Submissions made on behalf of
the petitioners may be summarised as
follows:

13.1 Although the proceedings
under Section 24 of the Code, 2006, which
are summary in nature, have already
culminated in final orders in favour of the
petitioners, the statutory authorities have
failed to execute the said orders, thereby
rendering
the
entire
proceedings
ineffective.

13.2
The
respondents
have
deliberately delayed execution, adopted
obstructive tactics, and failed to discharge
their statutory and administrative duties,
despite repeated requests.
1006 INDIAN LAW REPORTS ALLAHABAD SERIES
13.3
On
account
of
the
respondents
inaction,
the petitioners
continue to suffer, and the purpose of the
demarcation orders stand frustrated.

13.4 The acts and omissions of the
respondent authorities are arbitrary, illegal,
unreasonable,
and
contrary
to
the
provisions of the Code, 2006, warranting
interference by this Court.

State's Response

14. In response, learned Additional
Advocate General appearing for the Staterespondents has submitted that the Code,
2006 provides an exhaustive procedure to
deal with disputes regarding boundaries.
Section 24 of the Code, 2006 read with
Rule 22 of the U P Revenue Code Rules,
20163 delineates the procedural details
which are to be followed for demarcation
of boundaries. Referring to Section 24 of
the Code, 2006, it was submitted that on an
application,
raising
dispute
regarding
boundaries, the SDO, is to decide by a
summary enquiry, on the basis of existing
survey maps or, where they have been
revised in accordance with the provisions
of the Uttar Pradesh Consolidation of
Holdings Act, 1953, on the basis of such
maps, and if this is not possible, the
boundaries shall be fixed on the basis of
actual possession.

15. It was further submitted that as
per sub-section (2) of Section 24 of the
Code, 2006, if in the course of an inquiry
into a dispute under sub-section (1), the
SDO is unable to satisfy himself as to
which party is in possession or if it is
shown that possession has been obtained by
wrongful dispossession of the lawful
occupant, the SDO shall, in the first case,
ascertain by summary inquiry who is the
person best entitled to the property, and
shall put such person in possession; in the
second case, put the person so dispossessed
in possession, and for that purpose use or
cause to be used such force as may be
necessary and shall then fix the boundary
accordingly.

16. It was pointed out that the
procedure to be followed in this regard is
under Rule 22 of the Rules, 2016, which
provides that the demarcation report along
with site memo is to be prepared by the
Revenue Inspector, thereafter on receipt of
the said report, the SDO, after giving
opportunity to the concerned parties, and
fixing a date of hearing, is to pass an order.
The order so passed is thereafter to be
complied with by the Revenue Inspector
with a report being submitted to the SDO.

17. Learned Additional Advocate
General submits that the State Government
with an intent to ensure expeditious and
effective disposal of the matters, has issued
various Government Orders/Circulars from
time to time. It was pointed out that taking
note of the fact that the cases filed under
Section 24 of the Code, 2006 are being
disposed of/consigned to the record without
ensuring actual demarcation on the spot,
the
State
has
issued
circular
dated
16.12.2025, in order to ensure that after
passing of the order by the Sub-Divisional
Magistrate under Section 24 of the Code,
2006, the demarcation process is carried
out in accordance with law within the
specified time frame with a further
provision for physical verification of the
same. It is submitted that directives have
been
issued
to
obtain
geo-tagged
photographs along with the physical
verification report and to upload the same
on the RCCMS portal. It has also been
provided that strict action be initiated
12 All. Meena Devi Vs. State of U.P. & Ors.
1007
against the concerned officers if the
proceedings under Section 24 of the Code,
2006 are concluded without due physical
verification. A copy of the circular dated
16.12.2025 issued by the State Government
has been placed on record along with a
short Counter Affidavit filed on behalf of
the State-respondents.

Analysis and Discussion

18. In order to appreciate the rival
contentions, the provisions with regard to
settlement of boundary dispute contained in
Section 24 of the Code, 2006, are required
to be adverted. For ease of reference,
Section 24 of the Code, 2006 is being
extracted below:

 "24.
Disputes
regarding
boundaries. (1) The SDO may, on his own
motion or on an application made in this
behalf by a person interested, decide, by
summary inquiry, any dispute regarding
boundaries on the basis of existing survey
map or, where they have been revised in
accordance with the provisions of the Uttar
Pradesh Consolidation of Holding Act,
1953, on the basis of such maps, but if this
is not possible, the boundaries shall be
fixed on the basis of actual possession.

 (2) If in the course of an inquiry
into a dispute under sub- section (1), the
SDO is unable to satisfy himself as to
which party is in possession or if it is
shown that possession has been obtained by
wrongful dispossession of the lawful
occupant, the SDO shall -

 (a) in the first case, ascertain by
summary inquiry who is the person best
entitled to the property, and shall put such
person in possession;

 (b) in the second case, put the
person so dispossessed in possession, and
for that purpose use or cause to be used
such force as may be necessary and shall
then fix the boundary accordingly.

 (3) Every proceeding under this
section shall, as far as possible, be
concluded by the SDO within [three
months] from the date of the application.

 (4) Any person aggrieved by the
order of the SDO may prefer an appeal
before the Commissioner within 30 days of
the
such
order.
The
order
of
the
Commissioner
shall,
subject
to
the
provisions of Section 210, be final."

19. Rule 22 of the Rules, 2016,
which relates to settlement of boundary
dispute is also being reproduced below:

 22. Settlement of boundary
dispute [Section 24]. (1) Under section
24 (1) of the Code the tenure-holder shall
submit two copies of the application for
settlement of boundary dispute to the SubDivisional-Officer for one or more than one
contiguous gatas, and it shall contain the
following particulars:

 (a) Details of Gata Gata
number,
name
of
tenure
holder,
father/husbands name, name of village
/tehsil. If the tenure holders are more than
one, then particulars of all shall be
mentioned; current updated khatauni shall
also be attached to the application.

 (b) Details of contiguous Gata
Gata Number, name of tenure holder,
father/husbands
name,
name
of
village/tehsil. If the tenure holders are more
than one, then particulars of all shall be
1008 INDIAN LAW REPORTS ALLAHABAD SERIES
mentioned. Current updated khatauni shall
also be attached to the application.

 (2) If the khata is different in
khatauni, but sub-division is not done in
sazra-map, then sub-division in sazra-map
shall be necessary.

 (3) If boundary of any property of
Gram
Panchayat/State
Government
is
adjacent to gata/gatas to be demarcated,
then the Chairman, Land Management
Committee/Gram Pradhan and the State
Government shall be made a party in the
case.

 (4) Only the outer boundary shall
be demarcated for an application made for
boundary demarcation of continuous gatas.

 (5) The applicant shall deposit a
fee of Rs.1000/- in Government treasury
for the demarcation of gata/attached gatas.
A copy of challan receipt shall also be
attached with the application form.

 (6) On receipt of an application
for demarcation, on the same or next
working day, the Sub-Divisional-Officer
shall register the case in Revenue Court
Computerised
Management
System
(RCCMS). Three copies of notices shall be
issued from the computerized system and
will be delivered to the Revnue Inspector
through Tehsildar.

 (7) The Revenue Inspector shall
serve notice to the concerned tenure
holder/tenure holders as mentioned in subrule (1), through the Lekhpal or through
any other mode. In absence of the tenure
holders, notice will be served to the adult
family member of the tenure holder/tenure
holders. The information of demarcation
shall also be given to the Chairman, Land
Management Committee.

 (8) At the time of sending the
information or before the demarcation on
site, if the Revenue Inspector wants to
make any other affected person, a party to
the case he can do so.

 (9) After fixing the date of
demarcation and intimation to all the
concerned tenure holders, the Revenue
Inspector or any other revenue official will
demarcate the land, parcel or parcels, as the
case may be, During demarcation if any
affected tenure holder is not a party to the
case, such tenure holder shall be made a
party to the case by the Revenue Inspector
on the spot-And he will mention..the same
in his demarcation report. Demarcation
shall be completed within a month from the
date of order for the same by the SubDivisional-Officer.

 (10) The Revenue Inspector or other
revenue officials shall prepare the demarcation
report along with the site memo. If there are no
objections to the same, then after getting the
consent and signature of all the concerned
parties on the demarcation report, the same
shall be sent it to the Sub-Divisional-Officer
through Tehsildar in a week. On receipt of the
aforesaid report of the Revenue Inspector, the
Sub-Divisional-officer will pass the order
confirming the demarcation report.

 (11) If the affected parties to the
demarcation have not given their consent to
the demarcation, or if there is any objection
to the demarcation report, notice (s) will be
issued by the Sub-Divisional-Officer to all
the parties, fixing a date of hearing which
shall not be beyond 15 days from the date
of issuance of notice.
12 All. Meena Devi Vs. State of U.P. & Ors.
1009
 (12) The Sub-Divisional-Officer
shall pass an order on the matter of
boundary demarcation after hearing all the
concerned parties. The Revenue Inspector
shall comply with such order within two
weeks from the date of order, and shall
submit his report to the Sub-DivisionalOfficer.

 (13) Where the boundary of
gata/survey number is not recognizable due
to alluvion or diluvion of land, or heavy
rain, or due to damage caused by any
other reason, then on the application of
the
Chairman
of
village
Revenue
Committee of that village, or on the
report of the Revenue Inspector or
Lekhpal, or on the joint application
signed by all the concerned parties, the
Sub-Divisional-Officer shall instruct the
Revenue Inspector or Lekhpal by a
general or special order in writing, that
the demarcate the boundary on ground on
the basis of current survey map or, where
it is possible, on the basis of possession,
and if there is any complaint, then on the
advice of Village Revenue Committee,
resolve the same on the basis of mutual
consent. The Revenue Inspector or
Lekhpal shall comply with such order
within two weeks from the date of order,
and will submit his report to the SubDivisional- Officer.

 (14) At the time of passing order
for demarcation under sub-rules (10). (13)
ог (14), the Sub-Divisonal-Officer can
direct the SHO of the concerned police
station to make police force available on
the spot at the time of demarcation of land,
in order to maintain law and order.

 (15) The SDO, will try to
complete the process within the stipulated
time as mentioned in section 24(3) of the
Code and if the process is not completed
within such time then the reason for the
same shall be recorded."

20. It would be apposite to refer to
the Government Order dated 16.12.2025 in
terms of which, guidelines have been
issued for strict and effective compliance of
orders passed under Section 24. Relevant
extract of the said Government Order is as
follows:

 "4- mi;qZDr ds n`f"Vxr eq>s ;g dgus
dk funsZ'k gqvk gS fd /kkjk&24 ds oknksa ds
fuLrkj.k gsrq jktLo lafgrk] 2006@fu;ekoyh
2016 esa fofgr izkfo/kkuksa ds vuqdze esa fuEuor
fn'kk funsZ'kksa dk Hkh dM+kbZ ls vuqikyu lqfuf'pr
djk;k
tk;s%&
1-
m0iz0
jktLo
lafgrk@fu;ekoyh esa izkfo/kkfur O;oLFkk ds
vuqlkj /kkjk&24 ds okn esa miftykf/kdkjh }kjk
vkns'k ikfjr djus ds i'pkr HkkSfrd fpUgkadu
iRFkj ulc dh dk;Zokgh fu/kkZfjr le; esa
djkrs gq;s mDr dk;Zokgh dk HkkSfrd lR;kiu
vo'; djk;k tk;sA

 2- HkkSfrd fpUgkadu iRFkj ulc dh
dk;Zokgh fd;s tkus ds LFkyh; QksVksxzkQ ft;ks
yksds'ku lfgr izkIr fd;s tk;saA

 3- HkkSfrd fpUgkadu iRFkj ulc dh
dk;Zokgh dh lR;kiu vk[;k dks vkj0 lh0 lh0
,e0 ,l0 iksVZy ij viyksM djkus gsrq izk:i
fu/kkZfjr fd;s tkus dh O;oLFkk jktLo ifj"kn
}kjk 'kh?kz fodflr dh tk;sA

 4- HkkSfrd fpUgkadu iRFkj ulc dh
dk;Zokgh dk HkkSfrd lR;kiu djk;s fcuk i=koyh
nkf[kr nQ~rj djus gsrq mRrjnk;h vf/kdkfj;ksa ds
fo:} dBksj dk;Zokgh lqfuf'pr dh tk;sA"

(English Translation)

 "4. In view of the aforesaid, I am
directed to state that, in pursuance of the
provisions of the Uttar Pradesh Revenue
1010 INDIAN LAW REPORTS ALLAHABAD SERIES
Code 2006 /Rules, 2016 relating to the
disposal of cases under section 24, the
following guidelines shall also be strictly
adhered to:

 1.
In
accordance
with
the
provisions of the Uttar Pradesh Revenue
Code/Rules, upon the passing of an order
under section 24 by the Sub-Divisional
Magistrate, physical demarcation (Patthar
Nasab) shall be carried out within the
prescribed
time-limit,
and
physical
verification of the said demarcation shall be
mandatorily ensured.

 2.
On-site
photographs
with
embedded geo-location data shall be taken
for physical demarcation (Patthar Nasab).

 3. The Board of Revenue shall
expeditiously develop a prescribed format
for uploading the physical verification
report of the demarcation (Patthar Nasab)
process on the RCCMS portal.

 4. Strict disciplinary action shall
be initiated against the officers concerned
who consign the records without ensuring
physical
verification
of
the
physical
demarcation (Patthar Nasab)."

21. The present batch of writ
petitions bring to the fore a seemingly
systemic inaction of the concerned revenue
authorities. The petitions herein raise a
common grievance the non execution of
final demarcation orders passed under
Section 24 of the Code, 2006. Despite
having successfully navigated the statutory
procedures undergoing summary inquiries,
site
inspections,
and
obtaining
final
execution orders for affixation of boundary
marks, the petitioner find themselves to be
in a situation where the end relief remains
illusionary. The orders in their favour
remain on paper, unimplemented on the
spot due to inaction on part of the revenue
authorities.

The Mandate of Section 24

22. Section 24 of the Code, 2006
provides a statutory mechanism for the
resolution of disputes relating to boundaries
of land or villages through a summary
inquiry conducted by the SDO.

23. Under the said provision, the
SDO is empowered to initiate proceedings
either suo motu or on an application made
by an interested person and to decide such
disputes by adopting a summary procedure.
The determination of boundaries is required
to be made on the basis of existing survey
maps and, where such maps have been
revised
under
the
Uttar
Pradesh
Consolidation of Holdings Act, 1953, on
the basis of the revised maps. In situations
where boundary determination is not
feasible with reference to maps, the SDO is
mandated to fix boundaries on the basis of
actual possession.

24. During the course of the
inquiry, where the SDO is unable to satisfy
himself as to which party is in possession,
he is required to ascertain by summary
inquiry who is the person best entitled to
the property and to place such person in
possession. Further, if it is found that
possession has been obtained by wrongful
dispossession, the SDO is statutorily
obligated to restore possession to the
dispossessed party and is vested with the
authority to use such force as may be
necessary for that purpose, followed by
affixation of boundaries accordingly.

25. The proceedings under Section
24 are summary in nature and are required
12 All. Meena Devi Vs. State of U.P. & Ors.
1011
to be concluded, as far as practicable,
within a period of three months from the
date of application. Any person aggrieved
by an order passed by the SDO under this
section has a statutory right of appeal to the
Commissioner within thirty days from the
date of the order.

26. The scheme of Section 24 thus
underscores the legislative intent to provide
a speedy and effective mechanism for
resolution of boundary disputes, based on
documentary evidence in the form of
survey maps or, where necessary, on
evidence of actual possession.

Enforcement of Possession under
Section 24

27. Possession pursuant to an order
passed under Section 24 of the Uttar
Pradesh Revenue Code is an integral
component of the summary inquiry itself.
The SDO is expressly empowered to
restore or secure possession in favour of the
entitled party while deciding the boundary
dispute.

28. Where it is established that a
party has been wrongfully dispossessed, the
SDO is vested with the authority to restore
possession to the dispossessed person. The
provision further confers upon the SDO the
power to employ necessary force to give
effect
to
such
restoration,
thereby
combining
quasi-judicial
determination
with executive enforcement to ensure the
efficacy of the order.

29. Section 24 provides a speedy,
statutory
recourse
for
resolution
of
boundary disputes with direct possession
enforcement powers. In cases where
determination by reference to maps is not
possible, possession is required to be
assessed on the basis of actual physical
possession at the time of inquiry, and
boundaries are to be fixed accordingly. The
statutory object of Section 24 is to avoid
protracted litigation and to ensure prompt
resolution of boundary disputes along with
effective delivery of possession.

30. Although an appeal lies to the
Commissioner against an order passed
under Section 24, the order of the SDO,
including directions relating to possession,
remains operative and enforceable unless
stayed or set aside by the appellate
authority.

Time
Frame
for
Ensuring
Possession

31. Section 24 mandates that the
entire summary proceeding, including the
determination of boundaries and restoration
or
fixation
of
possession,
shall
be
completed, as far as possible, within a
period of three months from the date of the
application. The statutory timeline reflects
the legislative intent that possession must
be effectively ensured and the boundary
dispute settled within the three-month
window, ensuring a speedy resolution
mechanism. The SDO's order, including
possession restoration if required, should
ideally be executed within this time frame
to fulfill the mandate of expedited inquiry
under Section 24.

The procedural rigour of Rule 22

32. Rule 22 prescribes procedural
requirements for applications under Section
24, mandating the submission of updated
khatauni, particulars of all tenure holders,
and accurate reference to land parcels.
Compliance is mandatory for a valid
summary inquiry.
1012 INDIAN LAW REPORTS ALLAHABAD SERIES
33. In terms of Rule 22, an
application under Section 24(1) is required
to be submitted in duplicate before the
SDO.
The
application
must disclose
complete particulars of the disputed land,
including the Gata number, name of the
tenure holder, parentage or spousal details,
and the village and tehsil concerned. Where
the land is jointly held, particulars of all
tenure holders are required to be furnished.
The
application
must
further
be
accompanied by an updated khatauni of all
parties involved.

34. Where the dispute relates to
contiguous Gata numbers, the particulars of
such
adjoining
plots,
along
with
corresponding details of tenure holders and
updated khatauni records, are also required
to be annexed. In cases where the khata is
shown separately in the khatauni but no
corresponding sub-division exists in the
sazra map, Rule 22 mandates that such subdivision be carried out in the sazra map is
necessary.

35. Upon receipt of an application
for demarcation, the SDO is required, on
the same day or on the next working day, to
register the case in the Revenue Court
Computerized
Management
System
(RCCMS). Thereafter, three copies of the
notice
shall
be
generated
from
the
computerized system and to be delivered to
the
Revenue
Inspector
through
the
Tehsildar for due service and further
necessary action.

36.
The
Revenue
Inspector,
thereafter, is to ensure service of notice
upon the concerned tenure holder or tenure
holders, as referred to in sub-rule (1), either
through the Lekhpal or by any other mode.
In the event of absence of such tenure
holder or tenure holders, service of notice
is to be effected upon an adult member of
the family. The information regarding the
proposed
demarcation
is
to
be
communicated to the Chairman, Land
Management Committee.

37. The object underlying these
procedural requirements is to ensure that
complete information relating to the land in
dispute and the parties concerned is
available
before
the
SDO,
thereby
facilitating an effective and meaningful
summary inquiry.

38. Rule 22 has been consistently
interpreted as laying down mandatory
procedural requirements which must be
complied before proceedings under Section
24 can validly be undertaken. It has been
held that non-compliance with Rule 22,
including failure to file updated khatauni
records, omission to disclose particulars of
all tenure holders, or lack of clarity
regarding sub-division in the revenue map,
would
vitiate
the
summary
inquiry
contemplated under Section 24.

39. The SDO is required to satisfy
himself,
at
the
threshold,
that
the
application conforms to the requirements of
Rule 22, and only thereafter proceed to
adjudicate the boundary dispute.