The Telangana High Court has held the District Collector of Ranga Reddy in contempt of a court order to consider a representation seeking deletion of certain plots from the prohibitory properties list maintained under Section 22-A of the Registration Act, 1908.

While the court sentenced the Collector to six months' simple imprisonment along with fine of Rs. 2,000, it however suspended the sentence for four weeks. 

The single judge bench of Justice K. Lakshman, deciding the contempt plea on the basis of a previous direction to consider the representation within 60 days, noted as below in the order:

"...it is clear that the order under contempt passed by this Court directing the respondent to consider the request made by the petitioners in terms of the decision of 32 KL,J C.C. No.2900 of 2025 the then District Collector, Rangareddy District vide Lr.B/E4/4345/2021 dated 27.08.2022 and the consequential Memo No.15738/G1/2022 dated 02.09.2022 issued by the District Registrar, Rangareddy District, is not complied with. Pursuant to the said proceedings, adjacent plot and other two plots were deleted from the prohibitory list of properties under Section 22-A of the Act, 1908. Therefore, instead of implementing the order under contempt in such manner, the respondent had disobeyed the same, despite granting sufficient opportunity. Thus, the act of the respondent amounts to willful and deliberate disobedience and violation of the order under contempt. The explanation offered by the respondent is unsatisfactory and the same cannot be accepted".

For context, the petitioners had sought for a direction to the authorities to issue an NOC in respect of separate plots in Ranga Reddy District, in terms of the earlier proceedings in August 2022, which allowed to delete the plots from the Prohibitory Properties Register.

In August 2025, the writ court disposed of the petition, after directing the current Collector to consider the representation filed by them in 2024 to implement the 2022 Collector order and subsequent memo.

In the contempt plea, after perusing the material on record, the Court recorded that the order passed by the writ court was served on the collector in August 2025 itself, with a 60 day deadline for considering the representation. Post the lapse of the allotted timeline, a contempt case was filed on 15.10.2025.

“….it is evident that the respondent had knowledge with regard to the order under contempt. However, only after the contempt case was filed, the respondent had issued notices to the petitioners and passed the rejection order dated 26.02.2026. After passing the order, the respondent filed counter on 13.03.2026 contending that the RDO and the Tahsildar did not take any steps for reverting the possession to the declarant pursuant to the order dated 05.01.2004 passed by the LRT. ..”, the court inferred.

For further context, LRA No. 8 of 2022, filed by the State challenging the LRT order dated 05.01.2004 after a lapse of about 18 years, was dismissed on 25.04.2026 as barred by limitation.

The Court further found that a second rejection order dated 08.07.2026 was passed by the accused Collector after it once again directed reconsideration of representation following the dismissal of LRA[Land Revenue Appeal] No. 8 of 2022.

The Court also pointed out the discrepancies in the Collector's counter affidavit, which stated that on receipt of the High Court's order, notices were issued to the applicant and material was called for from the then Tahsildar and RDO. The court termed the aforesaid statement to be 'palpably false'.

“…Along with the counter dated 13.03.2026, the respondent filed the copy of notice dated 17.12.2025 and also issued another notice dated 18.02.2026. Hearing was held on 21.02.2026. The column of signatures of RDO, Tahsildar and Authorized Officer, was kept blank, however petitioner No.2 was present and, therefore, he signed in the relevant column. If the RDO, Tahsildar and Authorized Officer were present in the hearing conducted on 21.02.2026, they should have signed in the appropriate column…”, the court added further.

Further, the court pointed out that out of the disputed subject survey numbers, Survey No. 537 was deleted from the prohibitory list, while Survey Nos. 536, 657 and 658[the three subject plots] were retained.

“…There is also no explanation as to why the respondent deleted Survey No.537 out of the four subject survey numbers and several other survey numbers as per the order dated 05.01.2004 of the LRT….On one hand, the respondent deletes Survey No.537 and several other survey numbers from the prohibitory list of properties under Section 22-A of the Act, 1908 without following the procedure as contemplated under the Rules, 1974; while on the other hand, opposes the deletion of subject plots from Section 22-A of the Act, 1908 without any valid ground…”, the court pointed out/

The Collector, in the contempt plea, primarily took the defense that pursuant to the LRT order from 2004, no lands were reverted to the declarant under a panchanama in Form XI-A, and that unless the procedure under Rule 10A(6), 10A(7) and 10A(8) of the A.P. Land Reforms (Ceiling on Agricultural Holdings) Rules, 1974 was followed by the RDO and Tahsildar, the disputed lands could not be de-notified under Section 22-A.

The court opined that such defences cannot be agitated in contempt proceedings by relying on Jalim Singh v. Nand Kishore[2026] and Union of India v. Subedar Devassy PV[2006].

“…Rightness or wrongness of the order cannot be urged in contempt proceedings. Right or wrong, the order has to be obeyed. Flouting an order of the court would render the party liable for contempt...”, the court said further.

“…In the light of the aforesaid discussion, it is clear that the order under contempt passed by this Court… is not complied with… Thus, the act of the respondent amounts to willful and deliberate disobedience and violation of the order under contempt. The explanation offered by the respondent is unsatisfactory and the same cannot be accepted”, the Court concluded while allowing the contempt plea.