Allowing the appeal, the Court quashed the Rajasthan High Court’s judgment dated August 5, 2025, which had upheld the creation of the revenue villages “Amargarh” and “Sagatsar” in Barmer district.
The Bench of Justices PV Sanjay Kumar and Alok Aradhe restored the July 11, 2025 order of the Single Judge, which had invalidated the State’s notification for breaching a 2009 government circular prohibiting revenue villages from being named after persons, caste, religion, or community.
The dispute arose from a State notification dated December 31, 2020, issued under Section 16 of the Rajasthan Land Revenue Act, 1956, by which several new revenue villages were created, including Amargarh and Sagatsar, carved out of Meghwalon Ki Dhani in village Sohda, Barmer district.
Prior to the notification, the Tehsildar (Land Records), Gida, had certified that all procedural requirements were met and that the proposed villages were not associated with any individual, religion, caste, or community. Affidavits were also executed by private individuals agreeing to donate land for the proposed villages.
However, in 2025, during a process initiated by the Rural Development and Panchayati Raj Department for reorganisation and re-demarcation of gram panchayats, objections were raised by villagers of Meghwalon Ki Dhani. They alleged that the names “Amargarh” and “Sagatsar” were derived from the names of individuals Amarram and Sagat Singh, who had donated land for the villages.
The appellants approached the Rajasthan High Court challenging the 2020 notification. A Single Judge accepted the challenge, holding that naming revenue villages after individuals violated Clause 4 of the State Government’s circular dated August 20, 2009. The Single Judge quashed the notification insofar as it related to Amargarh and Sagatsar, while granting liberty to the State to rename the villages in accordance with law.
That decision was overturned by a Division Bench, which allowed an appeal filed by private respondents, holding that earlier High Court decisions on the issue could not be applied retrospectively to processes already concluded. The Division Bench reinstated the notification, prompting the present appeal before the Supreme Court.
Setting aside the Division Bench ruling, the Court held that Clause 4 of the 2009 circular was a binding policy decision and not merely directory in nature. The Court emphasised that the policy was framed to ensure communal harmony and expressly barred naming revenue villages after individuals, religion, caste, or sub-caste.
The Bench noted that it was undisputed that the names “Amargarh” and “Sagatsar” were derived from Amarram and Sagat Singh. As a result, the 2020 notification was in direct contravention of the State’s own policy. The Court held that the government could not act contrary to its policy unless it was lawfully amended or withdrawn, and any such deviation would be arbitrary and violative of Article 14 of the Constitution.
Rejecting the Division Bench’s narrow approach, the Supreme Court observed that pending litigation must be decided on merits and not limited solely to the applicability of prior judgments. It also dismissed arguments on lack of locus standi and retrospective reopening, holding that no legal sanctity could attach to a notification issued in breach of binding policy norms.
Consequently, the Court quashed the Division Bench judgment, restored the Single Judge’s order, and allowed the appeal, bringing the naming of the two revenue villages to an end unless renamed in accordance with law. No order as to costs was passed.
Case Title: Bhika Ram and Anr. v. State of Rajasthan & Ors.