High Court of DelhiCONT.CAS(C)/1499/2025

Pushpa Devi v. Shrikant R. Tapdiya, Sdm Alipur (North Delhi)

2026-04-02Hon'Ble Mr. Justice Sachin Datta4 pages

$~26 * IN THE HIGH COURT OF DELHI AT NEW DELHI + CONT.CAS(C) 1499/2025 PUSHPA DEVI .....Petitioner Through:

Mr. Sandeep Thukral, Advocate.

versus SHRIKANT R. TAPDIYA, SDM ALIPUR (NORTH DELHI) .....Respondent Through:

Ms. Harshita Nathrani, Mr. Aryaman, Advocates for Mr. Sameer Vashisht, SC, Civil, GNCTD along with Mr.

Aditya Kumar Jha, SDM, Narela.

CORAM:

HON'BLE MR. JUSTICE SACHIN DATTA % 02.04.2026

O R D E R

The present petition alleges wilful disobedience of the directions contained in the order dated 04.08.2025 passed in W.P.(C) 11588/2025. The said order reads as under:- "1. The petitioner has filed this writ petition under Article 226 of the Constitution seeking directions for the time-bound disposal of her representation dated 23.09.2024, addressed to the respondent - SubDivisional Magistrate ["SDM"], Alipur, Delhi.

2. By the aforesaid representation dated 23.09.2024, the petitioner seeks correction of the land record on the ground that the area has been erroneously shown as less than the actual area, and that there is also a mismatch in the khasra numbers.

3. Mr. Manashwy Jha, learned counsel for the respondent, who appears on advance notice, submits, upon instructions, that the village in question has been urbanised and, therefore, the relief sought falls outside the jurisdiction of the revenue authorities.

4. Mr. Kapil Kher, learned counsel for the petitioner, however, submits that the relief sought by the petitioner at this stage is only for consideration of her representation, and that all rights and contentions of the parties may be left open for adjudication. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

5. Having regard to this submission, Mr. Jha states that the petitioner's representation will be disposed of within four weeks from today.

6. The writ petition, alongwith pending application, is accordingly disposed of in terms of the above submission. It is made clear that all rights and contentions of the parties are left open." 2.

During the course of hearing, an affidavit of compliance has been furnished on behalf of the SDM, Narela, who is also present in Court. 3.

It is mentioned therein that the petitioner's representation dated 23.09.2024 has been duly considered and disposed of by way of a reasoned order. The said order dated 30.03.2026 has been enclosed along with the aforesaid affidavit. The same reads as under:- "Case Title: Representation dated 23.09.2024 filed by Smt. Pushpa Devi regarding correction of land records

ORDER

WHEREAS, vide representation dated 23.09.2024, Smt. Pushpa Devi submitted that she had purchased 1/4 th share in land comprised in Khasra Nos. 1894, 1895 and 1896 (total area measuring 15 Bigha 11 Biswa) vide registered sale deed dated 29.05.1984, and the same was duly mutated in her favour in Khatoni Pamaish entries dated 11.10.1985, 15.03.1986, 30.04.1986, 07.10.1986 and 12.03.1987, and that she was recorded as owner in possession of her share in the earlier revenue records; AND WHEREAS, the applicant further submitted that in the Khatoni for the year 2018-19, the land has been reflected under different Khasra numbers i.e.

94/28/A, 94/29 and 93/28/3, and that the total area has been reduced from 15 Bigha 11 Biswa to 15 Bigha 1 Biswa, allegedly affecting her share, and she has prayed for correction of the land records; AND WHEREAS, the Hon'ble High Court of Delhi in W.P.(C) No. 11588/2025 titled Pushpa Devi vs. Sub-Divisional Magistrate, North Delhi vide order dated 04.08.2025 was pleased to direct that the aforesaid representation dated 23.09.

AND WHEREAS, in compliance of the aforesaid directions, the matter has been examined and opportunity of hearing was afforded to the petitioner on 27.03.2026, wherein the petitioner reiterated the contents of her The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

representation;

AND WHEREAS, upon consideration of the material on record, it is observed that the relief sought by the applicant pertains to correction of entries involving questions relating to title, identity of land, and variation in khasra numbers and area.

AND WHEREAS, it is also pertinent that the provisions of the Delhi Land Reforms Act, 1954 have ceased to apply to the revenue estate of Alipur, Jindpur upon urbanization pursuant to notification issued under Section 507 of the Delhi Municipal Corporation Act, 1957; AND WHEREAS, the Hon'ble Supreme Court in Mohinder Singh (Dead) through LRs v. Narain Singh has categorically held that upon such urbanization, the applicability of the Delhi Land Reforms Act ceases and consequently the jurisdiction of Revenue Authorities under the said Act stands extinguished;

AND WHEREAS, in view of the aforesaid legal position, any adjudication sought by the applicant with respect to correction of revenue entries involving title and identity of land would be beyond the jurisdiction of this Court, and any such determination, if undertaken, would be without authority of law and non est in the eyes of law; NOW, THEREFORE, in view of the facts and circumstances of the case, applicable law, and judicial pronouncements cited hereinabove, the representation dated 23.09.2024 filed by Smt. Pushpa Devi, is hereby disposed of.

It is clarified that this order shall not be construed as an expression on the merits of the claim of ownership or entitlement of the applicant. Order accordingly."

Since the remit of the order dated 04.08.2025 was only that the SDM should decide the representation of the petitioner, and the same has now been decided, it cannot be said that there has been any wilful disobedience on the part of the respondents.

However, the petitioner is seriously aggrieved by the manner in which the representation has been decided. It is stated that the order passed does not adequately address the issue/s raised by the petitioner. Needless to say, The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

the petitioner would be at liberty to avail appropriate remedies, in accordance with law.

The petition is disposed of in the above terms. SACHIN DATTA, J APRIL 2, 2026/r The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.