Deepak & Another v. State of Chhattisgarh & Others, 2026

The petitioners challenged an order dated 17.03.2021 passed by the Tehsildar directing them to produce the Rin Pustika (land record booklet) relating to their land.

The Tehsildar had issued the direction solely on the basis of an application filed by Respondent No. 3, who was a private party.

The petitioners contended that the Chhattisgarh Land Revenue Code does not confer any authority on the Tehsildar to compel a party to produce documents merely because a private respondent seeks their production.

The petitioners further challenged the order dated 30.05.2022 passed by the Additional Collector, which affirmed the Tehsildar's order.

The respondents argued that the Tehsildar had rightly exercised his powers in directing production of the Rin Pustika for deciding the dispute.

The Court noted that the parties had been engaged in multiple litigations before the Civil Court, Revenue Authorities, and even the Supreme Court.

The High Court examined whether the Tehsildar possessed statutory authority under the Chhattisgarh Land Revenue Code to compel production of documents at the request of a private party.

The Chhattisgarh High Court allowed the writ petition.

The Court held that the Chhattisgarh Land Revenue Code does not authorize a Tehsildar to compel production of documents merely because a private respondent has filed an application.

It observed that filing an independent application seeking production of documents before the Tehsildar is foreign to the scheme of the Land Revenue Code.

The Court clarified that even if a party fails to produce documents, the Tehsildar's remedy is limited to drawing an adverse inference and not compelling production.

It held that the power to compel production of documents cannot be assumed in the absence of express statutory authority.

The Court observed that if production of documents becomes necessary in a properly instituted pending proceeding for adjudication, an order requiring their production may be legally sustainable.

Since no such circumstances existed in the present case, the Tehsildar exceeded his jurisdiction.

The Court found that the Additional Collector committed an error in affirming the Tehsildar's order.

Accordingly, both the orders dated 17.03.2021 and 30.05.2022 were quashed.

The judgment reinforces the principle that statutory authorities must act strictly within the powers conferred upon them by law.

The Court emphasized that administrative or revenue authorities cannot assume procedural powers that are not expressly provided under the governing statute.

By distinguishing between drawing an adverse inference and compelling production of documents, the Court clarified the limits of a Tehsildar's jurisdiction in revenue proceedings.

The ruling protects litigants from arbitrary procedural directions issued at the request of private parties without statutory backing.

The Court recognized that while production of documents may be necessary in certain judicial or quasi-judicial proceedings, such power must arise from an express legal provision or be exercised in accordance with established procedural law.

The decision strengthens the doctrine of limited statutory jurisdiction, ensuring that revenue authorities do not exceed their lawful powers.

The judgment is significant for future land revenue disputes as it prevents misuse of revenue proceedings to compel disclosure of documents outside the framework of the Chhattisgarh Land Revenue Code.

The ruling also underscores the importance of procedural fairness by ensuring that parties cannot be compelled to produce documents unless authorized by law.