Finality of Revenue Map Adjudications and the Limited Scope of Section 30, U.P. Revenue Code: Commentary on Suvej Singh v. Ram Naresh, 2025 INSC 1405

1. Introduction

The Supreme Court of India in Suvej Singh v. Ram Naresh & Ors., 2025 INSC 1405 (decided on 9 December 2025 by a Bench comprising Rajesh Bindal, J. and Manmohan, J.) has laid down an important clarification on:

The scope and limits of Section 30 of the Uttar Pradesh Revenue Code, 2006 (hereafter “the Code”) regarding maintenance and correction of revenue maps and field books; and
The circumstances in which the Supreme Court will interfere even with interlocutory remand orders of High Courts to avoid unnecessary and repetitive litigation.

The case arose out of a dispute concerning the precise location and map depiction of agricultural plot No. 22, which had already been settled in earlier revenue proceedings under the repealed U.P. Land Revenue Act, 1901 (“the 1901 Act”). Many years later, after the Code came into force, the private respondents attempted to reopen the same issue via an application under Section 30/38 of the Code, claiming a “correction” of the revenue map.

The core questions were:

Whether Section 30 of the Code permits a party to re-agitate and effectively relocate a plot whose location and map had been finally adjudicated upon years earlier under the 1901 Act; and
Whether the Supreme Court should interfere with a High Court order merely remanding the matter to the Collector for fresh consideration, especially when such remand is based on a misinterpretation of Section 30 and is likely to generate avoidable further litigation.

The judgment is significant for revenue practitioners, consolidations and land disputes, and for the broader jurisprudence on finality of decisions, res judicata-like principles in revenue matters, and judicial restraint on unnecessary remands.

2. Summary of the Judgment

2.1 Factual Background

Plot No. 22, with a total area of 0.18 D, had been subdivided and allotted after consolidation proceedings:
- The appellant, Suvej Singh, was in possession of and recorded owner of Plot Nos. 22/1 and 22/2, aggregating 0.12 D.
- The private respondents, including Ram Naresh (Respondent No. 1), were in possession of Plot No. 22/3, measuring 0.06 D, purchased from their vendors (Sanjay Jain and Bharat Jain, sons of Chandan Mal Jain).
After consolidation, the revenue map was finalized, reflecting the above locations and extents.

2.2 First Round of Litigation under the 1901 Act

The private respondents filed an application under Section 28 of the U.P. Land Revenue Act, 1901 seeking correction of the map with respect to Plot No. 22/3.
The Collector, Pilibhit, by order dated 27.05.1998, dismissed the application:
- He relied on a Commission’s report and a Naib Tehsildar’s report dated 21.08.1997, along with the attached nazari map.
- It was recorded that:
  - The appellant was in possession of Plots 22/1 and 22/2.
  - The respondents were in possession of Plot 22/3.
  - Respondent No. 1 had purchased 0.06 D from his vendors who could transfer only what they themselves owned and possessed.
- The Collector observed that there was no cause of action for the respondents to seek a map correction merely to change the location of the purchased plot, especially when they had bought it “with their eyes wide open” as to its location.
The private respondents appealed to the Additional Commissioner (Administration), who, on 04.09.2001, dismissed the appeal, upholding the Collector’s order. It was held that there was no error in the revenue map; the attempt was to obtain a new location for Respondent No. 1’s plot, which lay outside the scope of Section 28 of the 1901 Act.
No further challenge was made; the order dated 04.09.2001 thus attained finality.

2.3 Second Round under the U.P. Revenue Code, 2006

After about 17 years, and following the enforcement of the U.P. Revenue Code, 2006, the private respondents filed a fresh application dated 12.07.2018 under Section 30/38 of the Code, again seeking correction of the revenue map of Plot No. 22.
The Additional Collector (Judicial) (Respondent No. 4) by order dated 15.01.2020 rejected the application:
- He obtained a fresh report from the Naib Tehsildar dated 12.11.2018.
- He accepted the appellant’s preliminary objection that the respondents were trying to reopen an already settled issue.
- He held that the matter had been finally adjudicated in 1998/2001 and could not be raised again under the guise of “correction” under Section 30.
The Additional Commissioner (Administration) (Respondent No. 5), by order dated 25.04.2023, dismissed the appeal, reiterating that there was no justification to reopen a long-settled matter.

2.4 High Court Proceedings

The private respondents filed a writ petition before the Allahabad High Court challenging the orders dated 15.01.2020 and 25.04.2023.
By the impugned order dated 21.09.2023, the High Court:
- Set aside the orders of the Additional Collector (Judicial) and the Additional Commissioner (Administration); and
- Remanded the matter to the Additional Collector (Judicial) for fresh consideration, after affording a due opportunity of hearing to all parties.
- The High Court read Section 30 of the Code as conferring a continuing power and duty to maintain and correct maps annually, apparently undermining the application of finality/res judicata.

2.5 Supreme Court’s Decision

The Supreme Court allowed the appeal, set aside the High Court’s remand order, and effectively restored the orders of the revenue authorities. The Court held that:

Section 30 of the Code authorises the Collector to maintain maps and field books and to correct genuine errors or omissions. It does not permit a party to relocate a plot whose location has been finally adjudicated and mapped.
The earlier orders of 1998 and 2001 had finally settled the location of Plot Nos. 22/1, 22/2, and 22/3. A second application more than 17 years later was an impermissible attempt to reopen a concluded issue, motivated by a desire to obtain a better location (e.g., greater frontage on a wider road).
The High Court misread and misinterpreted Section 30. Its remand was based on an erroneous legal premise and would generate needless further litigation. In such circumstances, the Supreme Court was justified in interfering even with a remand order.
The appeal was therefore allowed, and the High Court’s order was set aside.

3. Analysis

3.1 Statutory Framework: From the 1901 Act to the 2006 Code

3.1.1 Section 28 of the U.P. Land Revenue Act, 1901

The original application by the private respondents was under Section 28 of the 1901 Act, which provided for correction of errors in maps and field-books. Under that regime:

Revenue authorities could correct mistakes, inaccuracies, and clerical/technical errors in mapping or recording.
But such power could not be used to completely relocate a plot or rewrite the results of consolidation and settlement proceedings, particularly once they had been contested and finalised.

The Collector and the Additional Commissioner in 1998 and 2001 effectively applied that principle, holding that the respondents were not pointing to any mapping error, but were seeking a different, more advantageous location for their plot, outside the scope of Section 28.

3.1.2 Section 30 of the U.P. Revenue Code, 2006

Section 30 of the Code, which replaced the 1901 Act, was central in the second round of litigation. The provision, as reproduced in the judgment, reads:

“30. Maintenance of Map and Field Book. –

(1) The Collector shall maintain, in the manner prescribed, a map and a field book (khasra) for each such village and shall cause to be recorded therein, annually, or at such longer intervals as may be prescribed, all changes in the boundaries of the village or survey numbers, and shall also cause to be corrected, any errors or omissions which are, from time to time, detected in such map or field book (khasra).

(2) The minjumla number shall be divided physically in the manner prescribed and revenue records including map and khasra shall be corrected accordingly.”

Two key aspects arise:

The maintenance duty – keeping maps and field books updated with changes in boundaries, survey numbers, and other developments on an annual or prescribed periodic basis.
The correction duty – detecting and correcting “errors or omissions” in the map or field book “from time to time”.

The High Court appears to have read this as conferring a broad, perpetual power to reopen past determinations, almost irrespective of prior adjudications. The Supreme Court decisively rejects this expansive interpretation.

3.2 Precedents Cited and Their Influence

3.2.1 Satyadhyan Ghosal & Ors. v. Deorajin Debi (Smt) & Anr. (AIR 1960 SC 941)

The private respondents relied on this judgment to argue that:

An order of remand is generally interlocutory.
Since the proceedings are not concluded, the Supreme Court ordinarily does not interfere with such orders under its appellate jurisdiction.

The Supreme Court in Suvej Singh acknowledges this principle but clarifies its limits. It notes that Satyadhyan Ghosal does not create an absolute bar against interfering with remand orders. Where:

the remand is founded on a clear misinterpretation of the law, and
its effect is to prolong or multiply litigation unnecessarily,

the Supreme Court is justified in intervening to correct the error immediately, rather than waiting for another round of proceedings.

3.2.2 M.C. Mehta v. Union of India & Ors. (1999) 6 SCC 237

This well-known environmental case is invoked here not for its environmental holdings, but for a broader procedural philosophy:

Courts should be mindful of the consequences of their orders on the duration and complexity of litigation.
They should avoid directions that unnecessarily reopen settled issues or create avoidable procedural loops.

In Suvej Singh, the citation supports the Court’s emphasis that unnecessary remands are themselves a source of injustice, as they protract disputes and impose additional costs on the parties and the system.

3.2.3 State of Uttar Pradesh v. Sudhir Kumar Singh & Ors. (2021) 19 SCC 706

This decision is a leading authority on the doctrine of natural justice and prejudice. It reaffirms that:

A violation of the audi alteram partem rule (right to be heard) does not automatically vitiate an order.
The party complaining of breach must demonstrate that the violation has caused prejudice, or at least that there was a reasonable likelihood of prejudice.
The so-called “useless formality” theory applies in appropriate cases: if a hearing would not have made any difference, setting aside or remanding solely for fresh hearing may be unnecessary.

In Suvej Singh, the Court cites Sudhir Kumar Singh to support a modern stance that:

Remand is not a mechanical consequence of any alleged procedural defect.
Courts must consider whether a remand would serve any real purpose, or merely delay the inevitable while burdening parties with more litigation.

3.2.4 Krishnadatt Awasthy v. State of Madhya Pradesh (2024 SCC OnLine SC 493)

This more recent Supreme Court decision (cited at para 17) reflects the same evolving approach:

Even where there are procedural or natural justice concerns, the Court may choose to decide the matter on merits at the appellate level, instead of sending the case back.
The overarching objective is to curtail litigation and bring finality where possible, instead of creating fresh rounds of proceedings.

In combination, these precedents empower the Supreme Court in Suvej Singh to step in and correct a legally unsustainable remand order, framing it as part of a contemporary judicial policy against multiplicity of litigation and redundant procedural cycles.

3.3 The Court’s Legal Reasoning

3.3.1 Interpretation of Section 30: Two Parts of a Single Duty

The Court’s central interpretive move lies in carefully reading Section 30(1) as composed of two related, but not disjunctive, components:

Maintenance and recording of changes:
- The Collector “shall maintain” the map and field book (khasra) for each village.
- He must “cause to be recorded” annually (or at longer prescribed intervals) all changes in:
  - Boundaries of villages; and
  - Survey numbers (i.e., parcel identifiers, subdivisions, amalgamations, etc.).
- Examples highlighted by the Court include:
  - Changes of ownership (sale, purchase, inheritance);
  - Exchange of land; and
  - Effects of consolidation proceedings on revenue records.
Correction of errors or omissions:
- Additionally, the Collector “shall also cause to be corrected, any errors or omissions which are, from time to time, detected” in the map or field book.
- The Court stresses the significance of the word “also”:
  - It shows that the second part is in addition to, and in continuation of, the first part.
  - It does not create an independent and unlimited revisional jurisdiction to reopen any and every settled dispute about maps.
- The “errors or omissions” contemplated are those that emerge in the process of maintaining accurate current records – e.g., clerical mistakes, mis-descriptions, or omissions – not judicially adjudicated boundary disputes.

Thus, Section 30 confers a continuous administrative duty to keep the revenue records accurate and up to date, but within the bounds of:

Recording actual changes (ownership, boundaries, consolidation outcomes), and
Correcting genuine errors or omissions, not reopening or overturning final judicial determinations.

3.3.2 Application to the Facts: “Correction” vs. “Relocation”

When the Supreme Court applies Section 30 to the specific facts, several points are decisive:

The map and location of Plot 22/3 had already been adjudicated.
- The Collector’s order in 1998, affirmed in 2001, was based on a Commission’s report, a Naib Tehsildar’s report, and a nazari map.
- Those proceedings conclusively determined:
  - Who was in possession of which sub-plot (22/1, 22/2, 22/3); and
  - The precise location and extent of each share.
- The private respondents did not challenge the 2001 order further; hence it attained finality.
The subsequent Section 30 application was not about any new “error” discovered in the records.
- The respondents did not identify:
  - A clerical mistake in area or boundaries;
  - An omission of an existing entry; or
  - Any discrepancy between the judicial determination and its reflection in the revenue map.
- Instead, they sought, in substance, a different location for their 0.06 D plot – “a better location” – presumably with greater road frontage or commercial advantage.
Changing a plot’s location is outside the scope of “correction” under Section 30.
- The Court clearly states that the private respondents’ effort was:
  
  “to change the location of the plot purchased by them, which may be more valuable. This does not fall within the scope of correction as envisaged under Section 30 of the Code.”
- Section 30 is not a route to re-argue what was already decided in 1998/2001 under the 1901 Act.
- The continuity of subject-matter and parties, and the earlier adjudication, create a functional res judicata/issue estoppel barrier, even though the Court does not use those exact terms in its own voice.

By drawing this line, the Supreme Court prevents Section 30 from being used as a disguised appeal or review, or as a mechanism to overcome the finality of earlier revenue decisions.

3.3.3 Finality and Abuse of Process

The Court is explicit that:

The private respondents bought their land from their vendors, who could transfer only what they owned and possessed.
The respondents did so “with their eyes wide open”, knowing the location and extent of the land.
Once they lost in 1998/2001, and did not pursue any further appeals or writs, they must be taken as having accepted the final position.

The second application filed 17 years later is viewed as:

An impermissible attempt to “reopen a settled issue”.
Motivated by the desire “to somehow get a better location” for the plot purchased by Respondent No. 1.
Outside the permissible ambit of Section 30 which is meant for maintenance and correction, not reallocation or upgradation of plot locations.

Though the judgment does not invoke “abuse of process” in explicit words, the reasoning strongly suggests that repeated applications seeking the same relief after long intervals, without new legal or factual grounds, amount to such abuse.

3.3.4 Correcting the High Court’s Misinterpretation of Section 30

The Supreme Court finds that the High Court:

“Misdirected itself” in dealing with the issues; and
“Misread and misinterpreted” Section 30 of the Code.

Specifically:

The High Court appears to have placed strong reliance on the fact that Section 30 requires the Collector to maintain and update maps and field books annually, or at prescribed intervals.
From this duty, it drew the inference that the Collector could, and should, re-examine the respondents’ grievance afresh, notwithstanding the earlier final adjudication.

The Supreme Court, however, clarifies that:

The annual or periodic duty of maintenance cannot be read as a licence to ignore final decisions rendered under the earlier statute.
The second part of Section 30 (correction of errors and omissions) is an extension of the first (maintenance and updating), not a fresh adjudicatory forum for concluded map disputes.
The High Court’s remand, therefore, rested on a fundamentally erroneous understanding of the statutory provision.

3.3.5 Approach to Remand Orders: From Automatic Remand to Reduction of Litigation

In paras 16–17, the Court confronts the argument that the Supreme Court should not interfere with a mere order of remand:

Earlier view:
- There was a tendency in earlier jurisprudence that, if there were violations of natural justice (e.g., denial of hearing), the usual remedy was to remand the matter for a fresh decision after granting a proper hearing.
Evolving view (supported by M.C. Mehta, Sudhir Kumar Singh, Krishnadatt Awasthy):
- The judiciary now emphasises:
  - Reducing multiplicity of litigation;
  - Avoiding futile or redundant remands;
  - Deciding matters on merits where the appellate court can do so, especially if no real prejudice would be caused by skipping a remand.
- An order of remand, though technically interlocutory, can be substantively problematic if it reopens settled issues on a wrong legal premise.

Applying this evolved approach, the Court in Suvej Singh holds:

Even though remand orders are generally not interfered with, this principle is not inflexible.
Here, the remand was based on a stark misinterpretation of Section 30 and would have the effect of forcing the appellant into a fresh, unnecessary round of litigation over an issue already decided two decades ago.
The Supreme Court therefore considers it necessary and appropriate to interfere at this stage to:
- Correct the legal error; and
- Prevent avoidable litigation, in line with the Court’s duty to curtail rather than generate disputes.

4. Impact of the Judgment

4.1 On Revenue Administration and Land Disputes in Uttar Pradesh

The decision has important implications for the operation of the U.P. Revenue Code, 2006, particularly Section 30:

Limited scope of “correction”:
- Revenue authorities must distinguish between:
  - Technical corrections (errors/omissions in map or khasra) and updating actual changes; and
  - Substantive re-litigation of boundary or location disputes previously decided.
- Only the former fall within Section 30; the latter are barred if already adjudicated.
Finality of earlier proceedings:
- Orders passed under the 1901 Act—especially after appeal—do not lose their finality merely because a new Code has come into force.
- Parties cannot use the Code as an opportunity to resurrect dead disputes through “correction” applications.
Discouragement of opportunistic map challenges:
- Attempts to improve the commercial or locational advantage of a plot under the guise of map correction are likely to be rejected as beyond Section 30.
- This promotes stability and certainty in land records, which is crucial for transactions, development, and dispute avoidance.

4.2 On Litigation Strategy and Res Judicata-like Principles

While the judgment does not explicitly frame the issue as one of res judicata, its underlying rationale reinforces that:

Once a particular issue—such as the location and extent of a plot—has been decided between the same parties by a competent authority and has attained finality, it cannot be reopened in a different guise (here, as a map “correction” under a different statute).
Practitioners must be cautious about advising clients to pursue fresh applications that essentially seek the same relief as earlier lost proceedings, particularly after significant time gaps.
High Courts, exercising supervisory jurisdiction under Article 226, must be alert to abuse of process via repeated litigations dressed in new statutory clothing.

4.3 On Judicial Attitude Towards Remands and Natural Justice

The judgment further cements a trend in Supreme Court jurisprudence:

Remand is no longer the default remedy even where some procedural concerns exist.
Court intervention, even at the stage of remand, is justified where:
- The lower court has clearly misinterpreted the governing statute; and
- The consequence would be a futile or redundant fresh round of litigation.
This aligns with the broader “prejudice test” in natural justice: without actual or likely prejudice, the system should avoid remands that serve only to delay and increase costs.

4.4 For Purchasers and Landholders

The Court’s observations also carry a cautionary message for purchasers of land:

Purchasers are deemed to buy land with their “eyes wide open” as to its location, area, and access.
Once they have purchased and had their rights adjudicated (if disputed), they cannot later demand relocation of the plot simply because another location may be more lucrative or desirable.
Due diligence at the time of purchase, and timely and proper challenge if any grievance exists, is critical; delayed re-litigation through map correction provisions will not be entertained.

5. Complex Concepts Simplified

5.1 “Map and Field Book (Khasra)”

Map: A graphical depiction of land parcels (plots/survey numbers) in a village, showing their shape, boundaries, and location with reference to roads, canals, etc.
Field Book / Khasra: A textual register listing each parcel with details such as:
- Survey number / plot number;
- Area (e.g. 0.18 D);
- Name of the recorded holder/tenure-holder;
- Natures of land (agricultural, residential, etc.).

Section 30 requires the Collector to keep both the map and khasra up to date.

5.2 “Minjumla”

The term minjumla (used in Section 30(2)) refers, roughly, to a combined or composite plot number created when several parcels are clubbed together for administrative convenience. Section 30(2) requires that when such a number is physically divided, the revenue records, including map and khasra, must be corrected accordingly.

5.3 “Nazari Map”

A nazari map is a site sketch or plan prepared on the spot—often by a revenue official like the Naib Tehsildar—showing:

Actual possession and boundaries as observed on the ground;
Relative position of plots and physical features.

In this case, the nazari map attached to the Naib Tehsildar’s 1997 report was a crucial basis for determining possession and location in 1998.

5.4 “Res Judicata” and Finality

Although the Court does not use the phrase extensively in its own reasoning, it reflects the essence of res judicata:

When a competent court/authority has finally decided an issue between the same parties, that issue cannot be reopened in fresh proceedings.
Even under a new law, if the subject-matter and relief are substantially the same, earlier final decisions act as a bar to re-litigation.

In revenue disputes, this ensures stability in title and location and prevents endless cycles of correction applications.

5.5 “Interlocutory Order” and “Remand”

An interlocutory order is an order passed in the middle of ongoing proceedings; it does not finally dispose of the case.
A remand order is a classic example: a higher court sends the matter back to a lower authority/court to reconsider or decide afresh.
While ordinarily such orders are not appealed to the Supreme Court, if the legal basis of the remand is clearly wrong and the remand would prolong the dispute without any real purpose, the Supreme Court can and does intervene.

5.6 Natural Justice and the “Useless Formality” Theory

Natural justice requires, among other things, that:

A person affected by an adverse order must be given a reasonable opportunity of being heard.

However, modern jurisprudence (as in Sudhir Kumar Singh) recognises that:

If granting a hearing would not have changed the outcome (e.g., because the law is clear and the facts undisputed), then setting aside an order and remanding solely for the sake of hearing may be a “useless formality”.
Court should look for prejudice: was any party actually prejudiced by the lack of hearing? If not, a remand may be unnecessary.

In Suvej Singh, this philosophy underpins the Court’s reluctance to endorse remands that would only generate litigation without substantive benefit.

6. Conclusion

Suvej Singh v. Ram Naresh is a noteworthy decision for several reasons:

It provides a clear and restrained interpretation of Section 30 of the U.P. Revenue Code, 2006, emphasising that:
- The Collector’s duty to maintain and correct maps and khasras is primarily administrative and technical;
- It does not empower revenue authorities to relitigate or relocate plots whose locations and extents have already been judicially determined and finalised.
It underscores the finality of earlier revenue proceedings under the 1901 Act, and prevents litigants from using new statutory frameworks as a backdoor to reopen old disputes—particularly after long periods of acquiescence.
It contributes to the evolving jurisprudence on remand orders and natural justice by affirming that:
- Remands are not automatic responses to procedural arguments;
- The Supreme Court will interfere even with interlocutory orders where a remand rests on a plainly erroneous reading of law and would cause multiplicity of litigation without substantive justification.
It sends a practical signal to litigants and practitioners that:
- Land purchases must be made with careful due diligence as to location and extent;
- Repeated attempts to upgrade one’s plot location under the guise of map “correction” are of no avail, especially when prior adjudications exist.

In the broader legal context, the judgment reinforces core values of the civil justice system—certainty, finality, and economy of litigation—while harmonising the transition from the 1901 Act to the 2006 Code. It stands as an important precedent in revenue law and procedural law, particularly in Uttar Pradesh, and will likely guide future courts in resisting attempts to stretch map correction powers beyond their legitimate purpose.