Disposed¶23

Manjeet Kumar v. Govt. of NCT of Delhi & Ors.

Delhi HC9 Feb 2026W.P.(C)/1771/2026

Case brief

AI extract

What is this about?

Regularisation of possession of village land (Khasra No. 19/16, Village Kharkhari Rond, 04 Bigha 16 Biswa); Gram Sabha allotment 1975 via BDO Najafgarh; LR Form No. 37 / Receipt No. 31; Khasra Girdawari 1987-88 entry; Bhumidhar declaration; Section 74(4) Delhi Land Reforms Act, 1954 application pending since 1998; urbanised land and jurisdiction of revenue authority; interim protection against dispossession denied; remedy lies before competent forum; writ petition disposed of, rights and contentions reserved.

What did the court decide?

The Court declined to entertain the writ petition: a party asserting proprietary rights on the basis of an alleged allotment and revenue entries must avail appropriate remedies in accordance with law before the competent forum. ¶18

Manjeet Kumar Vs Govt. of NCT of Delhi & Ors. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Disposed

¶23

Issue for consideration

Whether the Respondents should be directed to regularise the Petitioner's possession of land comprised in Khasra No. 19/16, Village Kharkhari Rond, measuring 04 Bigha 16 Biswa. +1 more

¶11

Court's answer

¶18

Ratio / Principle

No imminent or demonstrable threat of dispossession had been placed on record, and the chronology from 1998 to 2026 disclosed no intervening event establishing lawful recognition of the Petitioner's status as Bhumidhar or validating his possession; accordingly, the prayer for interim protection of possession had to be urged before the forum competent to adjudicate the substantive relief of regularisation.

¶18

Detailed headnote1 paragraphs

Writ Petition (Civil) before the High Court of Delhi (Sanjeev Narula, J.), disposed of on 09.02.2026. Manjeet Kumar sought directions to the Govt. of NCT of Delhi and others to regularise his possession of land in Khasra No. 19/16, Village Kharkhari Rond (04 Bigha 16 Biswa), relying on a Gram Sabha allotment of 30.10.1975 made through the BDO, Najafgarh (LR Form No. 37, Receipt No. 31), its purported recording in the 1987-88 Khasra Girdawari, and a 1998 application under Section 74(4) of the Delhi Land Reforms Act, 1954 for declaration of Bhumidhar status which remained unanswered and without any formal order of rejection. The Court noted the factum of urbanisation of the land, found no imminent or demonstrable threat of dispossession on record, and observed that the 1998-2026 chronology disclosed no lawful recognition of the Petitioner as Bhumidhar. It held that proprietary claims founded on the alleged allotment and revenue entries must be pursued through appropriate remedies before the competent forum, and that any plea for interim protection of possession must likewise be urged there. The petition was disposed of along with pending applications, with all rights and contentions of the Petitioner reserved to be agitated before the appropriate forum.

¶1

$~72

¶2

IN THE HIGH COURT OF DELHI AT NEW DELHI

¶3

- W.P.(C) 1771/2026 & CM APPLs. 8618-8619/2026

¶4

MANJEET KUMAR .....Petitioner

¶5

Through: Mr. Ayaz Ahmed, Advocate.

¶6

versus

¶7

GOVT. OF NCT OF DELHI & ORS. .....Respondents Through: Ms. Deeksha L. Kakar, Mr. Rashneet Singh and Ms. Sana Parveen, Advocates for R-4.

¶8

CORAM:

¶9

HON'BLE MR. JUSTICE SANJEEV NARULA

¶10

O R D E R % 09.02.2026

¶11

This writ petition seeks issuance of directions to the Respondents to regularise Petitioner’s possession in respect of land comprised in Khasra No. 19/16, situated in the revenue estate of Village Kharkhari Rond, Delhi, measuring 04 Bigha 16 Biswa.

¶12

It is the case of the Petitioner that on 30^th October, 1975, the subject land was allotted for agricultural purposes to his grandmother by the Gram Sabha through the BDO, Najafgarh, and LR Form No. 37 bearing Receipt No. 31 was issued in that regard. It is further asserted that the said allotment finds mention in the Khasra Girdawari (revenue records) of Village Kharkhari Rond for the year 1987-88.

¶13

The Petitioner states that on 25^th March, 1998, he preferred an application under Section 74(4) of the Delhi Land Reforms Act, 1954

¶14

This is a digitally signed order.

¶15

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 13/02/2026 at 11:15:12

¶16

seeking declaration of his status as Bhumidhar; however no response was received thereto.

¶17

Aggrieved, the Petitioner has approached this Court. On a pointed query as to the status of the aforesaid application under Section 74(4), counsel for the Petitioner submits that no formal order of rejection has been passed and, to his knowledge, the application remains pending. It is, however, contended that in view of the urbanisation of the land, the competent revenue authority would lack jurisdiction to decide the same. In these circumstances, a prayer is made that Respondents No. 1 to 4 be directed to regularise the Petitioner’s possession over the subject land.

¶18

The Court has considered submissions advanced by the Petitioner. The factum of urbanisation of the land is not in dispute. In view thereof, if the Petitioner seeks to assert proprietary rights on the basis of the alleged allotment and revenue entries, he would necessarily be required to avail appropriate remedies in accordance with law before the competent forum. As on date, no imminent or demonstrable threat of dispossession has been placed on record. The application under Section 74(4) itself dates back to the year 1998, and the list of dates spanning from 1998 till 2026 does not disclose any intervening event establishing lawful recognition of the Petitioner’s status as Bhumidhar or otherwise validating his possession. This prayer for interim protection in respect of possession would have to be urged before the forum competent where the Petitioner seek to adjudicate the substantive relief of regularisation of land status.

¶19

In light of the foregoing, the Court is not inclined to entertain the present petition.

¶20

This is a digitally signed order.

¶21

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 13/02/2026 at 11:15:12

¶22

All rights and contentions of the Petitioner are reserved to be agitated before the appropriate forum.

¶23

Disposed of along with pending applications.

¶24

SANJEEV NARULA, J

¶25

FEBRUARY 9, 2026

¶26

¶27

This is a digitally signed order.

¶28

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 13/02/2026 at 11:15:12

Manjeet Kumar v. Govt. of NCT of Delhi & Ors.

Case brief

What is this about?

What did the court decide?

Manjeet Kumar v. Govt. of NCT of Delhi & Ors.

Case brief

What is this about?

What did the court decide?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

Similar cases

Anuj Vs Delhi Urban Shelter Improvement Board

Sri Saudan Singh Institute of Higher Education Vs National Council for Teacher Education & Anr.

Chandrabali Singh Urmila Mahavidyalaya Vs National Council for Teacher Education Andanr

Indradev Institute of Education and Technology Vs National Council for Teacher Education & Anr.

Gulshan Kumar and Others Vs Municipal Corporation of Delhi and Another

Gurbir Singh Vs Delhi Development Authority (Dda)

Pradeep Vs Municipal Corporation of Delhi and Ors.

Worldwide Rail Journeys Pvt. Ltd. Vs Rajasthan Tourism Development Corporation Ltd.

Rahul Mani Vs the Union of India & Ors.

Pawan Kumar Vs Allahabad Bank

Amardeep Sharma Vs Biotechnology Industry Research Assistance Council

Umesh Prasad Sah Hathi Vs Jawaharlal Nehru University & Ors.

Preeti Mathur Vs Directorate of Education

Saty Pal & Ors. Vs Institute of Nuclear Medicine and Allied Science Thr Head Works Inmas & Ors.