The Telangana High Court has sentenced the District Collector of Ranga Reddy district to six months of simple imprisonment for wilfully disobeying its direction to consider a representation seeking the removal of certain land parcels from the prohibitory properties list maintained under Section 22-A of the Registration Act, 1908.
Justice K. Lakshman, while allowing a contempt petition, imposed a fine of ₹2,000 on the Collector and held that his conduct amounted to deliberate and wilful disobedience of the Court’s earlier order. However, the Court suspended the sentence for four weeks.
The contempt proceedings arose from the Collector’s failure to comply with an August 2025 order directing him to consider the petitioners’ representation within 60 days. The representation sought implementation of an earlier decision taken by the then District Collector in August 2022, followed by a consequential memorandum issued by the District Registrar in September 2022, permitting the deletion of certain plots from the prohibitory properties register.
The petitioners had approached the authorities seeking no-objection certificates in respect of their respective land parcels, relying on the earlier administrative proceedings. While certain adjoining plots had already been removed from the prohibitory list, the disputed properties continued to remain under restriction.
The writ petition was disposed of in August 2025 with a direction to the incumbent Collector to examine the petitioners’ representation and take an appropriate decision within the stipulated 60-day period. Despite being served with the order in August 2025, the Collector failed to act within the prescribed timeframe, prompting the petitioners to institute contempt proceedings on October 15, 2025.
The High Court noted that the Collector issued notices to the petitioners only after the contempt proceedings had been initiated. An order rejecting their representation was eventually passed on February 26, 2026. A subsequent rejection order was also issued on July 8, 2026, even after the Court had again directed reconsideration of the matter following the dismissal of a State appeal.
The Court found serious inconsistencies in the Collector’s explanation and the statements made in his counter-affidavit. It observed that although the Collector claimed to have sought reports from the Revenue Divisional Officer (RDO) and the Tahsildar and conducted a hearing, the relevant records did not support this assertion.
Taking note of the hearing proceedings dated February 21, 2026, the Court pointed out that the columns meant for the signatures of the RDO, Tahsildar and Authorised Officer had been left blank, even though the Collector’s affidavit suggested that the authorities had participated in the proceedings. The Court termed the statement made in the counter-affidavit regarding the proceedings as ‘palpably false’.
The Court also highlighted the inconsistency in the treatment of the disputed survey numbers. Of the four survey numbers initially in question, Survey No. 537 had been removed from the prohibitory properties list, while Survey Nos. 536, 657 and 658 continued to remain on it.
It questioned the absence of any justification for deleting one survey number and several other parcels from the prohibitory list while refusing to extend similar treatment to the petitioners’ lands, despite the earlier order of the Land Reforms Tribunal (LRT) dated January 5, 2004.
The Collector had sought to justify his decision by contending that the lands had not been restored to the declarant through a panchnama in Form XI-A, as contemplated under the Andhra Pradesh Land Reforms (Ceiling on Agricultural Holdings) Rules, 1974. He argued that the requisite procedure under Rules 10A(6), 10A(7) and 10A(8) had not been completed by the revenue authorities and, therefore, the disputed lands could not be removed from the prohibitory list under Section 22-A.
Rejecting this defence, the High Court held that the correctness or otherwise of the earlier judicial direction could not be reopened in contempt proceedings. Relying on the Supreme Court’s decisions in Jalim Singh v. Nand Kishore (2026) and Union of India v. Subedar Devassy P.V. (2006), the Court reiterated that a party against whom a judicial order has been passed cannot refuse to comply with it by questioning its legal correctness.
“Rightness or wrongness of the order cannot be urged in contempt proceedings. Right or wrong, the order has to be obeyed,” the Court observed.
The Court also took note of the fact that the State’s challenge to the LRT order dated January 5, 2004, through Land Revenue Appeal No. 8 of 2022, had been dismissed on April 25, 2026, on the ground of limitation, after being instituted nearly 18 years later.
Finding that the Collector had sufficient knowledge of the judicial direction but failed to implement it despite being afforded adequate opportunity, the High Court concluded that his conduct constituted wilful and deliberate disobedience of the Court’s order.
Holding the explanation furnished by the Collector to be unsatisfactory, the Court allowed the contempt petition and sentenced him to six months of simple imprisonment along with a fine of ₹2,000. The sentence, however, was suspended for four weeks.
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