“Reasonable-Time Limitation” under the Karnataka PTCL Act:
Supreme Court clarifies that restoration petitions must be filed within a reasonable period

1. Introduction

The Supreme Court’s decision in Shardhamma & Anr. v. Deputy Commissioner & Ors. (2025 INSC 583, decided on 29 April 2025) marks an important clarification on the temporal boundaries for initiating proceedings under the Karnataka Scheduled Castes and Scheduled Tribes (Prohibition of Transfer of Certain Lands) Act, 1978 (“PTCL Act”).

The appellants, Shardhamma and her son (successors-in-interest of a purchaser), challenged orders of the Assistant Commissioner, Deputy Commissioner and the Karnataka High Court which had directed restoration of land to a third-party relative of the original grantee. The core issues before the Supreme Court were:

• Whether a petition under Section 5 of the PTCL Act filed 23 years after the impugned transfer, and 14 years after the Act came into force, is barred by delay and laches; and
• Whether the sale violated the non-alienation clause contained in the Saguvalli Chit (grant certificate) which prescribed a 10-year bar on transfers.

2. Summary of the Judgment

Allowing the appeal, the Court (Per Satish Chandra Sharma, J. concurring with B. V. Nagarathna, J.) held:

1. The restoration petition filed on 06 June 1992—more than two decades after the alienation of 20 June 1969—was filed after an unreasonably long period and is therefore liable to be dismissed for delay and laches, notwithstanding that the PTCL Act does not expressly prescribe a limitation period.
2. The Saguvalli Chit revealed only a 10-year non-alienation clause; hence, the 1969 sale (23 years after grant) did not violate the clause.
3. The respondent-petitioner seeking restoration lacked locus standi as he was not a legal heir of the original grantee.
4. Orders of the Revenue Authorities and the High Court were consequently quashed, and the appellants’ title was confirmed.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

1. Nekkanti Rama Lakshmi v. State of Karnataka, (2020) 14 SCC 232
   • Reiterated that although Section 5 PTCL Act prescribes no limitation, applications (or suo motu action) must be brought within a “reasonable time”.
   • The Court relied on paragraphs 7-8 of Nekkanti to overrule earlier Karnataka Full Bench views that allowed petitions “at any time”.
2. Vivek M. Hinduja v. M. Ashwatha, (2020) 14 SCC 228
   • Held that where no period of limitation is prescribed, parties (and authorities) must act within a reasonable time; belated actions are fatal.
   • Affirmed the broader principle from Pune Municipal Corporation v. State of Maharashtra (2007) 5 SCC 211 that declaratory relief may be refused when sought after limitation.
3. Earlier Karnataka HC decisions overruled
   • R. Rudrappa v. Commissioner (1998), Maddurappa v. State of Karnataka (2006) and G. Maregouda v. Commissioner (2000) had held absence of limitation under Section 5 PTCL Act permitted petitions at any time. The Supreme Court reaffirmed their overruling in Nekkanti.

3.2 Legal Reasoning Adopted by the Court

1. Doctrine of Reasonable Time – Drawing from precedent, the Court applied the equitable principle that statutory silence on limitation cannot permit indefinite revival of stale claims. It balanced legislative intent (protection of SC/ST grantees) with certainty of land titles, ultimately finding a 23-year delay unreasonable.

2. Interpretation of Grant Conditions – The Court closely examined the vernacular Saguvalli Chit. Unlike some earlier cases where a 15- or 20-year bar existed, this document restricted alienation only for 10 years. As the sale occurred after 23 years, the transfer was legally valid.

3. Locus Standi – Section 5 empowers only the “original grantee or his successor” to seek restoration. Because the respondent was a collateral relative, not a legal heir, he lacked standing. The Court thus underscored the requirement of a direct lineal relationship.

3.3 Impact of the Judgment

• Clarity on Limitation: Confirms that “reasonable time” is now an entrenched filter for PTCL petitions. Future litigants must act promptly, likely within 12-15 years of alienation (guidance drawn from Nekkanti & Vivek Hinduja).
• Due Diligence for Land Transactions: Purchasers of granted lands can draw comfort once the reasonable period lapses, reducing market uncertainty.
• Administrative Guidance: Revenue authorities must refuse to entertain stale applications or take suo-motu action after long delays.
• Locus Enforcement: Collateral relatives or “interested persons” without heirship can no longer jeopardise settled titles under PTCL Act.
• Grant-specific Approach: Courts must scrutinise the Saguvalli Chit or grant order to ascertain the exact period of non-alienation rather than apply a blanket 15- or 20-year rule.

4. Complex Concepts Simplified

• PTCL Act (1978): A Karnataka statute prohibiting transfer of certain lands granted to SC/ST persons without Government permission and providing for restoration of such lands if illegally alienated.
• Section 5 Petition: Mechanism through which the grantee or heir seeks annulment of an illegal transfer and restoration of possession.
• Delay and Laches: An equitable doctrine where a claim can be denied if the claimant’s inaction for an unreasonable period prejudices the opposite party, even when no statutory limitation is provided.
• Saguvalli Chit: A regional term for the certificate or order of grant issued by the State, containing conditions such as non-alienation clauses.
• Non-alienation Clause: A condition restraining the grantee from selling or encumbering the land for a specified period (here, 10 years) to protect vulnerable beneficiaries.
• Locus Standi: The right to bring an action or to be heard in a court. Under PTCL, only the original grantee or his lawful heirs have locus to seek restoration.

5. Conclusion

The Supreme Court’s ruling in Shardhamma is significant for three reasons: (i) it entrenches the “reasonable-time” limitation on PTCL applications, safeguarding settled property titles; (ii) it mandates rigorous scrutiny of grant documents to ascertain the true non-alienation period; and (iii) it restricts standing to genuine successors of the grantee. Collectively, the Judgment balances social-welfare goals of the PTCL Act with the imperatives of legal certainty and equity in land transactions, and is poised to guide lower courts and revenue authorities in disposing of similar disputes efficiently.