ORDER : 1. In the present batch of the petitions, since common questions are involved, therefore, at the request of counsel for the parties, these petitions have been heard together and are being decided by the present order. 2. These writ petitions have been filed by the petitioners challenging the notifications dated 20.11.2025 and 28.12.2025 issued by the respondents in relation to delimitation of various Gram Panchayats, Panchayat Samitis, and Zila Parishads; change of their headquarters; merger of one Gram Panchayat with another; inclusion or exclusion of villages from one Gram Panchayat to another. 3. The facts, as prayed, have been noticed from D.B. Civil Writ Petition No.988/2025. In the first round of litigation, several writ petitions (CWP-7781/2025-Sheela Kumari Vs. State of Raj. & Ors., & other petitions) were filed before this Court challenging the initiation of the process of delimitation of Gram Panchayats, Panchayat Samities and Zila Parishads by the State Government. The said writ petitions were decided by a Coordinate Bench of this Court vide order dated 14.11.2025 directing the respondents to conclude the process of delimitation by 31.12.2025 with a further direction to hold the elections of all the local bodies, including Panchayats and Municipalities, on or before 15.04.2026. The order dated 14.11.2025 passed by the Coordinate Bench of this Court was challenged by some of the writ petitioners before the Hon’ble Supreme Court by filing of Special Leave Petition No. 36874 of 2025 (Sanyam Lodha v. State of Rajasthan & Ors.), wherein the State Government gave an undertaking to conclude the elections by 15.04.2026 and the said SLP was dismissed by the Hon’ble Supreme Court vide order dated 19-12-2025. The aforesaid order 14.11.2025 passed by the Division Bench of this Court was also challenged by some of the writ petitioners before the Hon’ble Supreme Court by filing of Special Leave to Appeal No.34/2026 (Villagers of Revenue Village Singhaniya & Anr Vs. State of Rajasthan & Ors.) and the said SLP was also dismissed by the Hon’ble Supreme Court granting liberty to the aggrieved persons to approach the competent authority with regard to shifting of headquarters. Subsequently, in furtherance of the earlier notification issued under Sections 9, 10, & 101 of the Rajasthan Panchayati Raj Act, 1994 (hereinafter referred to as “the Act of 1994”), the respondents issued another notification dated 20.11.2025.
Subsequently, in furtherance of the earlier notification issued under Sections 9, 10, & 101 of the Rajasthan Panchayati Raj Act, 1994 (hereinafter referred to as “the Act of 1994”), the respondents issued another notification dated 20.11.2025. After conclusion of the proceedings, a further notification dated 28.12.2025 was issued for correction of clerical mistakes as well as for considering the representations and making additional amendments in the earlier notification. Both these notifications dated 20.11.2025 & 28.12.2025, as stated above, have been challenged in the present batch of the petitions. 4. Learned counsels appearing on behalf of the petitioners argued that by issuance of the notifications impugned herein, the respondents have included their villages in other Gram Panchayats without any justifiable reason. They further argued that the headquarters of certain Gram Panchayats have been shifted arbitrarily from one village to another without any administrative exigency. They further argued that the respondents have failed to follow their own guidelines governing the inclusion or exclusion of villages from one Gram Panchayat to another or from one Panchayat Samiti to another. They further argued that some villages have been attached to the Gram Panchayats situated at a distance of more than 6 km, which is in violation of their own guidelines. They further argued that the respondents have issued the impugned notifications, ignoring the report submitted by the District Collector, which was favourable to the petitioners. Counsels further argued that the respondents have adopted a pick and choose policy while including or excluding villages from particular Gram Panchayats. Counsels further argued that no prior notice was issued to the affected villagers before issuance of the impugned notifications. Counsels further argued that the action taken by the respondents reflects total non-application of mind and the entire exercise has been carried out in an arbitrary manner, just to give benefit to their own people. Counsels further argued that the respondents have not followed the procedure prescribed under Sections 9,10, 101 & 115 of the Act of 1994. Counsels further argued that the respondents failed to consider that certain Panchayat headquarters had been functioning in particular villages for more than 50 years.
Counsels further argued that the respondents have not followed the procedure prescribed under Sections 9,10, 101 & 115 of the Act of 1994. Counsels further argued that the respondents failed to consider that certain Panchayat headquarters had been functioning in particular villages for more than 50 years. Counsels further argued that there was no administrative exigency warranting the change of Panchayat headquarters while giving effect to such changes and the respondents failed to consider the relevant and material facts such as the existence of primary health centres, post offices, banks, and the proximity of villages to State and National Highways. 5. In support of their contentions, learned counsels relied upon the judgment passed by the Hon’ble Supreme in the matter of Telangana Housing Board v. Azamunnisa Begum reported in (2018) 7 SCC 346 , wherein paras No.48 & 49, it has been held as under:- “48. That apart, the correction of the alleged clerical error does not give rise to the argument that only 661.04 acres was acquired out of 687.03 acres. If the correction gives rise to an argument or contention, then it ceases to be the correction of a clerical error but is really the correction of a substantive error, which does not come within the purview of Section 87 of the Act. 49. Be that as it may, in Tata Consulting Engineers v. Workmen [Tata Consulting Engineers v. Workmen, 1980 Supp SCC 627 : 1981 SCC (L&S) 407] Pathak, J. adverted to a clerical error and held in para 20 of the report as follows: (SCC p. 637) “20. … The jurisdiction given to the [Industrial] Tribunal by Rule 31 [Industrial Disputes (Bombay) Rules, 1957] is closely circumscribed. It is only a clerical mistake or error which can be corrected, and the clerical mistake or error must arise from an accidental slip or omission in the award. An accidental slip or omission implies that something was intended and contrary to that intention what should not have been included has been included or what should have been included has been omitted. It must be a mistake or error amenable to clerical correction only. It must not be a mistake or error which calls for rectification by modification of the conscious adjudication on the issues involved.” 6.
It must be a mistake or error amenable to clerical correction only. It must not be a mistake or error which calls for rectification by modification of the conscious adjudication on the issues involved.” 6. Learned counsels further relied upon the judgment passed by the Hon’ble Supreme Court in the matter of Shayara Bano v. Union of India reported in 2017 (9) SCC 1 , wherein para No.95, it has been held as under:- 95. On a reading of this judgment in Natural Resources Allocation case [Natural Resources Allocation, In re, Special Reference No. 1 of 2012, (2012) 10 SCC 1 ] , it is clear that this Court did not read McDowell [State of A.P. v. McDowell and Co., (1996) 3 SCC 709 ] as being an authority for the proposition that legislation can never be struck down as being arbitrary. Indeed the Court, after referring to all the earlier judgments, and Ajay Hasia [Ajay Hasia v. Khalid Mujib Sehravardi, (1981) 1 SCC 722 : 1981 SCC (L&S) 258] in particular, which stated that legislation can be struck down on the ground that it is “arbitrary” under Article 14, went on to conclude that “arbitrariness” when applied to legislation cannot be used loosely. Instead, it broad based the test, stating that if a constitutional infirmity is found, Article 14 will interdict such infirmity. And a constitutional infirmity is found in Article 14 itself whenever legislation is “manifestly arbitrary” i.e. when it is not fair, not reasonable, discriminatory, not transparent, capricious, biased, with favouritism or nepotism and not in pursuit of promotion of healthy competition and equitable treatment. Positively speaking, it should conform to norms which are rational, informed with reason and guided by public interest, etc.” 7. Learned counsels further relied upon the judgment passed by the Hon’ble Supreme Court in the matter of Atma Singh v. State of Punjab , reported in 1981 (2) SCC 657 , wherein para Nos.7 & 11, it has been held as under:- 7. The whole purpose of delimitation of municipalities into wards is to ensure that every citizen should get a fair representation in the municipalities.
The whole purpose of delimitation of municipalities into wards is to ensure that every citizen should get a fair representation in the municipalities. When a municipality is reconstituted by the inclusion of any local area within the limits of a municipality under sub-section (3) of Section 5 or by the exclusion of any local area from the limits of a municipality under Section 7, i.e. when there is an alteration of the limits of the municipality, there must of necessity be a division of the reconstituted municipality into new wards without which the elections cannot be held. There can be no disenfranchisement of a part of the electorate of a municipality. The question was dealt with at some length by the Gujarat High Court in Bhaichandbhai Maganlal Shah v. State of Gujarat [8 Guj LR 210 (Guj HC)] and it was observed: “It must follow logically and inevitably from this proposition that the constitution of wards dividing the whole of the municipal district is a sine qua non of a valid election. If no wards at all are constituted, in the municipal district, the machinery of election cannot go through and equally the machinery of election cannot go through if wards are constituted in respect of a part of the municipal district and the other part is not divided into any ward or wards. In such a case there would be lists of voters for the wards which are constituted out of a part of the municipal district but there would be no lists of voters so far as the other part of the municipal district is concerned and no one from that part would be qualified to vote or to stand as a candidate for the election and no Councillors being elected by that part, there would be no representation of that part on the municipality. Where such a situation arises, it is difficult to see how the municipality can be said to be a municipality for the whole of the municipal district within the meaning of Section 9.” We approve of the view taken by the Gujarat High Court. 11.
Where such a situation arises, it is difficult to see how the municipality can be said to be a municipality for the whole of the municipal district within the meaning of Section 9.” We approve of the view taken by the Gujarat High Court. 11. We are distressed to find that due to the stay order passed by the Division Bench a large number of inhabitants of the local areas brought within the municipal limits under sub-section (3) of Section 5 of the Act, who were otherwise eligible to be enrolled as voters, have thereby been deprived not only of their valuable right to vote at the election but also of the right to contest as a candidate for election as a Councillor from any of the wards of the municipality or to the office of the President or the Vice-President. But there is little that can be done in the matter at this stage. 8. Learned counsels further relied upon the judgment passed by the Hon’ble Supreme Court in the matter of State of M.P. Vs. Devilal , reported in 1986 (1) SCC 657 wherein paras No.12 to 15, it has been held as under:- 12. A close and combined reading of these provisions and the other provisions of the Act which follow hereafter make it quite evident that the actual control over the Gram Panchayat in a block is through the Janapada Panchayat for the block. It would also appear that the result of the elections to the Janapada Panchayat would depend upon the nature of the electoral roll prepared for each constituency in a block. If the State Government were to issue a notification under sub-section (1) of Section 106 of the Act for redistribution of the constituencies in a block after the process of election has started, it would necessarily change the whole pattern of voting in the election of members to the Janapada Panchayat. This is plainly a typical case of gerrymandering. As is well known, “gerrymander” is an American expression which has taken root in the English language, meaning to arrange election districts so as to give an unfair advantage to the party in power by means of a redistribution act or to manipulate constituencies generally. 13.
This is plainly a typical case of gerrymandering. As is well known, “gerrymander” is an American expression which has taken root in the English language, meaning to arrange election districts so as to give an unfair advantage to the party in power by means of a redistribution act or to manipulate constituencies generally. 13. Question of delimitation of constituencies in a block under sub-section (1) of Section 106 of the Act is connected with the holding of election of members to the Janapada Panchayat. Question of delimitation of such constituencies would necessarily arise when there is alteration in the limits of a Gram Sabha area under sub-section (2) of Section 361 of the Act which brings about a change in a block or alteration in the limits of the block, under sub-section (4) of Section 370. It is not necessary for us to go into details except to refer to certain relevant provisions. Amalgamation, splitting up and alteration in the limits of Gram Sabhas have to be carried out after following the procedure prescribed by Sections 360 and 361. Section 362 provides that where a notification under Section 361 has been issued, the State Government may make such consequential orders as it may deem fit in respect of (a) the constitution of the Gram Sabha and the Gram Panchayat for the altered area where a local area has been included in or excluded from a Gram Sabha; (b) for the dissolution of the existing Gram Sabhas which have been amalgamated and the Gram Panchayats or subordinate agencies thereof, as the case may be, and the constitution of the amalgamated Gram Sabha and Gram Panchayat thereafter; (c) the dissolution of the Gram Sabhas split up and the constitution of the Gram Sabhas established in its place and the constitution of the Gram Panchayats thereafter and matters ancillary thereto. 14. Alteration of the limits of a block can be effected by the State Government after following the procedure prescribed in Section 370 of the Act. Sub-section (1) of Section 370 provides that the State Government may, by notification, signify its intention to alter the limits of a block by including therein any local area in the vicinity thereof or by excluding therefrom any local area comprised therein.
Sub-section (1) of Section 370 provides that the State Government may, by notification, signify its intention to alter the limits of a block by including therein any local area in the vicinity thereof or by excluding therefrom any local area comprised therein. Sub-section (2) provides that every such notification shall define the limits of the local area which is intended to be included in or excluded from a block. Sub-section (3) provides that any inhabitant of the area or areas affected by a notification under sub-section (1) may, if he objects to anything therein contained, submit his objection in writing to the State Government within 60 days of the publication of the notification and the State Government shall take his objection into consideration. Sub-section (4) provides that when 60 days from the date of publication of the notification have expired and the State Government has considered and passed orders on such objections as may have been submitted to it within the said period, the State Government may, by notification, include the local area or any part thereof in the block or exclude it therefrom. Section 371 provides that on the issue of a notification under sub-section (4) of Section 370, the State Government may make such consequential orders as it may deem fit in respect of (i) the constitution of Janapada Panchayat for the altered area, etc. When there is an alteration in the limits of a Gram Sabha area under sub- section (2) of Section 361 or in the limits of a block under sub-section (4) of Section 370, it may be that the State Government would have to issue the requisite notification for delimitation of the constituencies of such altered block under sub-section (1) of Section 106 of the Act. 15. In the instant case, there was no alteration either in the limits of the Gram Sabha area under sub-section (2) of Section 361 or of the block under sub-section (4) of Section 370 and therefore no occasion for the State Government to issue a fresh notification under sub-section (1) of Section 106 of the Act purporting to restructure the constituencies of the block.
We have no doubt in our mind that the impugned notification dated November 25, 1970 issued by the State Government seeking to alter the constituencies of the blocks after the process of election of members to the Janapada Panchayat had started and that by the Collector dated November 29, 1970 for the reallocation of the reserved seats for the members of Scheduled Castes and Scheduled Tribes were wholly mala fide and intended and meant to gain control over the Janapada Panchayat and were therefore liable to be struck down. 9. Learned counsels further relied upon the judgment passed by this High Court in the matter of Bhanwar Lal Mundra and Ors. vs. The State of Rajasthan and Ors. , reported in 2013 (3) WLC (Raj.) 255 wherein para Nos.23 & 26, it has been held as under:- “23. In the present case, we find that the Gram Panchayat Napasar has matured itself into an urban area and with almost all the urban facilities available in Napasar, it has moved on the path of urbanization and was declared as Municipality Class IV by the State Government. The right to development has been recognized to be included in the right to life guaranteed under Article 21 of the Constitution of India. It is a component of right to life. It cannot be treated as a mere right to economic betterment and includes within it an umbrella of fundamental human right such as civil, political, cultural and social process, right to health, education and for decent and clean environment, vide N.D. Jayal v. Union of India (MANU/SC/0649/2003 : (2004) 9 SCC 362 ), in which reliance was placed on Samatha v. State of A.P. (1997) 8 SCC 191 ) and Madhu Kishwar v. State of Bihar : (1996) 5 SCC 125 ). In Election Commission of India v. St. Mary's School (2008)2 SCC 390 ), it was held that the right to development is a valuable human right. 26. For the aforesaid reasons, we are of the considered view that the Notification dated 18.9.2009 issued by the State Government withdrawing the Notification dated 6.10.2008 declaring village Panchayat Napasar as Municipality Class-IV, is illegal, arbitrary and has been issued by the State Government with oblique and retrograde purpose, for which it did not have any power to advice the Governor to issue such Notification.
The impugned Notification is declared unconstitutional being violative of Article 21 and Article 243Q in Part-IX-A of the Constitution of India as inserted by Constitution (Seventy-fourth Amendment) Act, 1992 with effect from 1.6.1993. It is also declared to be a retrograde step of governance by the State Government, which cannot be sustained in law. 10. Learned counsels further relied upon the judgment passed by the Hon’ble Supreme Court in the matter of State of Punjab Vs. Darshan Singh reported in 2004 (1) SCC 328 . 11. Lastly, learned counsels for petitioners prayed for allowing the writ petitions and quashing the impugned notifications. 12. Mr. Rajendra Prasad, (Senior Counsel) learned Advocate General along with Mr. Kapil Prakash Mathur, learned Additional Advocate General appearing on behalf of the respondents opposed the submissions made on behalf of the petitioners and argued that the issue involved in these writ petitions has already been considered and decided by the Coordinate Bench of this Court in the matter of Sheela Kumari (supra), which does not require any further adjudication by this Court. In para nos.91, 110, 148, 150, 165, 166, 167, 201, 207 & 224 of the judgment passed in the matter of Sheela Kumari (supra) it has been held as under :- “91. In various writ petitions, final notification issued under Section 101 of the Act of 1994 as well as under Section 3 of the Act of 2009 regarding delimitation of Panchayat area as well as delimitation of Municipal area respectively, are challenged on various grounds. Apart from countering the averments made in the writ petition on merits, various preliminary objections were raised by the respondent regarding maintainability of the said writ petitions. The learned Advocate General submitted that in view of the constitutional as well as statutory bar of interference, the writ petitions against the final notification of delimitation are not maintainable. In view of the rival submissions, following questions emanates for adjudication by this Court. 1. Whether the writ petitions are maintainable against the final notifications of Delimitation, in view of the Bar of interference provided under Constitution of India as well as provisions of respective statutes? 2. What is the scope of judicial review under Article 226 of the Constitution of India in the matters relating to Delimitation notifications? 3.
1. Whether the writ petitions are maintainable against the final notifications of Delimitation, in view of the Bar of interference provided under Constitution of India as well as provisions of respective statutes? 2. What is the scope of judicial review under Article 226 of the Constitution of India in the matters relating to Delimitation notifications? 3. Whether the guidelines issued by the State Government for undertaking process of delimitation are statutory in nature and therefore, required to be followed strictly? 4. Whether the petitioners have locus to maintain the writ petition challenging the delimitation notification? 5. Whether the State Government is under obligation to decide the objections submitted by the petitioners regarding the proposed delimitation while adhering to the principles of audi alteram partem 6. Whether the writ petitions challenging the validity of delimitation notifications issued under Section 101 of the Act of 1994 and Section 3 of the Act of 2009 are sustainable in view of the grounds raised therein? 110. Having considered the rival submissions, this Court finds merit in the argument advanced by the learned Advocate General. The term “in prescribed manner” used under Section 101(1) read with Section 2(xix) as well as Section 102 of the Act of 1994 clearly provides that for the purpose of infusing statutory force to any order or guidelines under the Act of 1994, the same must be laid down by way of rules made in accordance with the Act and notified in the Official Gazette. The guidelines relied upon by the petitioners have not undergone such statutory process. They are neither framed under any rule-making power nor published as rules in the Gazette, and hence, they cannot be regarded as possessing statutory character. Accordingly, the Court holds that the guidelines in question are purely administrative in nature, intended only to facilitate internal procedural compliance, lacking statutory force and thus, not enforceable under the law. Mere non- adherence of the guiding principle cannot be a valid ground to question the final delimitation notification. 148. The conclusion emerges from the discussions made above, can be summed up as under :- i) The power of the Government in issuing delimitation notifications is in the nature of conditional legislation.
Mere non- adherence of the guiding principle cannot be a valid ground to question the final delimitation notification. 148. The conclusion emerges from the discussions made above, can be summed up as under :- i) The power of the Government in issuing delimitation notifications is in the nature of conditional legislation. ii) The scope of interference by the Constitutional Court in the matters of delimitation is limited to the scope of judicial review and the same can only be exercised in rarest of rare cases on establishment of proof of manifest arbitrariness or the decision being irreconcilable to the Constitutional values. iii) The guidelines issued along with the notices for delimitation are not statutory in nature and thus, are not enforceable in law. iv) The final delimitation notifications once issued, cannot be interfered with merely on the ground of non-adherence of the guidelines relating to population / distance criteria alone, where the decision has been taken after holistic consideration of various factors as per the constitutional scheme. v) The writ petitions challenging the delimitation notifications cannot be dismissed merely on the ground of locus standi of the petitioners. vi) The authorities considering the objections / suggestions received in pursuance of the notices of delimitation, are not required to act as a judicial / quasi-judicial authority to decide each objections with reasoned order. vii) The principle of audi alteram partem is not applicable in the cases of delimitation. viii) In view of the discussions made above, with regard to different grounds raised by the petitioners in different writ petitions, as adjudicated above, no case for interference in the present bunch of writ petitions challenging the final notifications of delimitation issued under Section 3 of the Act of 2009 or under Section 101 of the Act of 1994, is made out. 150. A large bunch of writ petitions was filed challenging the process so undertaken in pursuance of notification dated 10.01.2025 and also the proposals made in pursuance thereof. The challenge has been made on various common grounds including non-adherence of the guidelines issued along with the notice, alleged problems to be faced by the villagers, non-consideration of the objections submitted by the villagers or arbitrary exercise of powers on political considerations. 165.
The challenge has been made on various common grounds including non-adherence of the guidelines issued along with the notice, alleged problems to be faced by the villagers, non-consideration of the objections submitted by the villagers or arbitrary exercise of powers on political considerations. 165. As discussed in the earlier part of this Judgment, the process of delimitation is in the nature of conditional legislation and the authority undertaking the same i.e. three Members High Level Committee in the present case, is not supposed to act as a judicial or quasi-judicial authority. Similarly, the representations made by the villagers are only in the form of the suggestions and there is no statutory requirement to adjudicate the objections and decide each such objections with reasoned order. As held above, the recommendations made or decision taken by the committee are not amenable to writ jurisdiction except within the limited scope of judicial review. Therefore, the directions contained in para 7 and 8 of the order dated 23.05.2025 cannot be allowed to sustain. However, it is expected from the State Government to comply with the statement made before the learned Single Judge as recorded in Para 2 and 3 of the said order. 166. We have also considered D.B. Civil Writ Petition (PIL) No.9199/2025 (Sanwar Mal Choudhary & Ors. Vs. State of Rajasthan & Ors.), wherein the petitioners have alleged that the District Collector, Sikar, while forwarding the final proposal to the State Government, failed to include the name of Reengus as a new Panchayat Samiti and confined the recommendation only to the reconstitution of Khandela Panchayat Samiti, thereby ignoring the proposal made by the Block Development Officer and the representations submitted by several Gram Panchayats. Per contra, learned Advocate General submitted that the delimitation exercise is undertaken strictly in accordance with law and after due consideration of all relevant factors. It was contended that the proposal for creation of Reengus Panchayat Samiti did not satisfy the criteria of population and administrative viability as per the prescribed norms, and therefore, was not recommended. It was further argued that the matter falls within the realm of administrative discretion, and unless malafide or manifest arbitrariness is shown, judicial interference is unwarranted. It is further argued that even otherwise, the process of consideration for reconstituting the Panchayat Samiti is still not finalized, therefore, no interference at this stage is called for. 167.
It was further argued that the matter falls within the realm of administrative discretion, and unless malafide or manifest arbitrariness is shown, judicial interference is unwarranted. It is further argued that even otherwise, the process of consideration for reconstituting the Panchayat Samiti is still not finalized, therefore, no interference at this stage is called for. 167. As held above, the interference of this Court at this premature stage is not called for. The disputes as raised in the writ petition regarding adequacy and viability of creation of Reengus as a Panchayat Samiti cannot be decided by this Court. As directed above, all the pending proposals regarding delimitation shall be considered by the High Level Committee. 201. Learned counsel for the petitioners argued that the guidelines issued by the State on 10.01.2025 and 13.02.2025 have been disregarded. It was submitted that these guidelines mandate that headquarters of a newly created Gram Panchayat should, as far as possible, be established in a village with adequate means of transportation to ensure convenient access for all residents of the Gram Panchayat concerned. It was further contended that the designated village must have government offices and other essential facilities, including a School, Panchayat Bhawan, Anganwadi Center, Patwar Bhawan and Kisan Seva Sadan, for which sufficient land ought to be available. However, it is submitted that in the present matter, the prescribed 6 km distance parameter and other foundational guidelines for delimitation have been violated. The petitioners assert that there was no administrative necessity to conduct the current delimitation exercise, rendering it arbitrary. 207. Accordingly, this Court holds that non- observance or deviation from the guidelines does not vitiate impugned delimitation process or the determination of the Gram Panchayat headquarters. The petitioners, therefore, fail to establish any illegality or procedural infirmity warranting interference in the exercise of powers of judicial review. 224.1 In view of the adjudication made and conclusion drawn in Part-A of the judgment, the writ petitions challenging the final notifications issued under Section 3 of the Act of 2009 as well as Section 101 of the Act of 1994, are dismissed. 224.2 In view of the adjudication made and conclusion drawn in Part-B of the judgment, D.B. Civil Special Appeal (Writ) No.831/2025 (State of Rajasthan and Ors. Vs.
224.2 In view of the adjudication made and conclusion drawn in Part-B of the judgment, D.B. Civil Special Appeal (Writ) No.831/2025 (State of Rajasthan and Ors. Vs. Dhanna Ram and Ors.) and other special appeals challenging the interim order dated 23.05.2025 to the extent of Para 7 & 8 of the same, are allowed. All the writ petitions challenging the process of delimitation initiated in pursuance of the notices issued under Section 101 of the Act of 1994, are dismissed. It is directed that the concerned District Collectors shall send the proposal for delimitation to the state Government and the three members high-level committee constituted for the purpose of examining the same, shall take final decision upon the proposals for delimitation so sent by the concerned District Collectors in an objective manner. The State Government shall complete the entire exercise of delimitation on or before 31.12.2025. 224.3 In view of the adjudication made and conclusion drawn in Part-C of the judgment, the writ petitions challenging the process of delimitation/change of boundaries of the municipal wards in absence of change of census or change in the number of wards or change in the territorial boundaries of the municipality, are allowed. The respondents are directed not to effect any change in the internal boundaries of the municipal wards in such cases. Consequently, D.B. Special Appeal (Writ) No.1005/2025 (State of Rajasthan & Ors. Vs Narayan Singh Solanki & Ors.) filed for challenging the interim order dated 11.06.2025, is hereby dismissed. 224.4 In view of the adjudication made and conclusion drawn in Part-D of the judgment, the writ petitions challenging removal of Panchayat Samiti Member / Pradhan, on account of delimitation of respective areas / wards, are hereby dismissed. 224.5 In view of the adjudication made and conclusion drawn in Part-E of the judgment, the writ petitions relating to appointment of the administrator, are dismissed. 224.6 In view of the adjudication made and conclusion drawn in Part-F of the judgment, the writ petitions praying for fixing/nominating the village headquarter are dismissed. 224.7 In view of the adjudication made and conclusion drawn in Part-G of the judgment, D. B. Civil Writ Petition (PIL) No.4686/2025 [Sanyam Lodha Vs.
224.6 In view of the adjudication made and conclusion drawn in Part-F of the judgment, the writ petitions praying for fixing/nominating the village headquarter are dismissed. 224.7 In view of the adjudication made and conclusion drawn in Part-G of the judgment, D. B. Civil Writ Petition (PIL) No.4686/2025 [Sanyam Lodha Vs. State of Rajasthan] as well as D. B. Civil Writ Petition No. 1285/2025 (Giriraj Singh Devanda vs. State of Rajasthan & ors.) praying for a direction for holding the elections of Municipality or Panchayati Raj Institutions, respectively, are disposed of with a direction to the State Government that after completing the delimitation exercise, elections of all the Local Self Bodies i.e. Panchayats as well as Municipality, shall immediately be conducted simultaneously and the entire exercise for such elections shall be completed on or before 15.04.2026. 224.8 To promote the spirit of ‘Save Paper – Save Environment’, the Registry of this Court is directed that, while placing a copy of this judgment in concerned files as well as while processing applications for issuance of certified copies of this judgment pertaining to any specific writ petition or special appeal, it shall issue a certified copy comprising the first page of the judgment, the relevant page showing the cause title of the respective writ petition/special appeal, and the full text of the judgment beginning from Page No.288 of this judgment. 224.9 Stay applications and all pending application(s), if any, shall also stand disposed of. 224.10 A copy of this judgment shall be kept in each connected file. 13. He further submits that the aforesaid judgment came to be challenged before the Hon’ble Supreme Court in the matter of Villagers of Revenue Village Singhaniya & Anr. Vs. State of Rajasthan & Ors. (Special Leave to Appeal (C) No.34/2026) and the Hon’ble Supreme Court while dismissing the SLP on 05.01.2026 passed the following order:- “1. We have heard learned counsel for the petitioners as well as Mr. K.M. Natraj, learned ASG on behalf of the State of Rajasthan and other official respondents. 2. In our considered opinion, no case to interfere with the administrative exercise of delimitation undertaken by the State of Rajasthan for the purpose of reconstitution of Gram Panchayat, is made out. Furthermore, we find that the High Court has thoroughly examined all the factual and legal aspects, and no infringement of any constitutional or legally vested right has been identified.
In our considered opinion, no case to interfere with the administrative exercise of delimitation undertaken by the State of Rajasthan for the purpose of reconstitution of Gram Panchayat, is made out. Furthermore, we find that the High Court has thoroughly examined all the factual and legal aspects, and no infringement of any constitutional or legally vested right has been identified. The special leave petition is, accordingly, dismissed. 3. It goes without saying that if the Gram Panchayat faces any difficulty in its management or in providing services to the village residents, it will be at liberty to approach the competent authority to shift its headquarters. 4. Pending application(s), if any, shall stand closed. 14. He further relied upon the judgment passed by the Hon’ble Supreme Court in the matter of Sanyam Lodha Vs. State of Rajasthan (Special Leave to Appeal (C) No(s). 36874/2025) decided on 19.12.2025, wherein it has been held as under:- 1. We have heard learned senior counsel for the petitioner. Mr. K.M. Natraj, learned Additional Solicitor General has also entered appearance on behalf of the State of Rajasthan. 2. In view of the fact that the delimitation exercise is near completion and the High Court has already issued a positive direction to conclude the elections by 15.04.2026, we see no reason to entertain this special leave petition. The same is, accordingly, dismissed. 3. However, learned senior counsel for the petitioner submits that there is a genuine apprehension that the elections are likely to be further postponed. On this, Mr. K.M. Natraj states that, as per his instructions, the State Government is committed to conclude the elections by 15.04.2026. 4. In the event of any delay due to some unforeseen circumstances, the parties, for that limited purpose, may approach the High Court. 5. Pending application(s), if any, shall stand closed.” 15. He further submits that the notification dated 28.12.2025, which has been challenged in the present writ petitions has also been challenged before the Coordinate Bench of this Court in D.B. Civil Writ Petition (PIL) No.538/2026 titled as Ratan Lal Palsaniya & Ors. Vs. The State of Rajasthan & Ors., and the said writ petition has been dismissed by the Co-ordinate Bench of this Court vide order dated 13.01.2026, which read as under:- 1. Heard. 2.
Vs. The State of Rajasthan & Ors., and the said writ petition has been dismissed by the Co-ordinate Bench of this Court vide order dated 13.01.2026, which read as under:- 1. Heard. 2. The prayer made in this petition is as follows: “I. Issue an appropriate order or direction in the nature of certiorari, quashing and setting aside the Notification dated 28.12.2025 bearing No. issued by the Rural Development and Panchayati Raj Department, Government of Rajasthan, to the limited extent it separates Gram Panchayat Chandeli ka Bas-Puniyana from Panchayat Samiti Dantaramgarh and includes it in the newly Constituted Panchayat Samiti Khachariyawas, District Sikar. II. Issue an appropriate writ, order or direction in the nature of mandamus, directing the Respondents to retain/restore Gram Panchayat Chandeli ka Bas - Puniyana within the jurisdiction of Panchayat Samiti Dantaramgarh, District Sikar, in accordance with law and keeping in view contiguity, distance and administrative convenience. III. In the alternative, issue an appropriate order or direction directing the Respondents to recon- sider the placement of Gram Panchayat Chandeli ka Bas - Puniyana after affording due opportu- nity of hearing to the residents of the concerned Gram Panchayat and to pass a reasoned and speaking order within a time-bound period. IV. Pass such other and further orders as this Hon'ble Court may deem fit and proper in the facts and circumstances of the case.” 3. Considering the aspects raised in this petition, we notice that in the judgment dated 14.11.2025 passed in the case of Sheela Kumari Vs. State of Rajasthan & Ors. (D.B. Civil Writ Petition No.7718/2025) and other connected matters, this Court has upheld the power of the State Govern- ment in conducting the exercise relating to the de- limitation aspect and the involvement of the people of the concerned village has also been discussed at length. We have been informed that the said judg- ment stands upheld by the Hon’ble Supreme Court in the case of Villagers of Revenue Village Sing- haniya & Anr. Vs. State of Rajasthan & Ors. [Petition(s) for Special Leave to Appeal (C) No.34/2026] vide order dated 05.01.2026. 4. In view thereto, the issue raised in this peti- tion need not be again examined by this Court and the writ petition stands disposed of in the same terms as Sheela Kumari (supra). 5.
Vs. State of Rajasthan & Ors. [Petition(s) for Special Leave to Appeal (C) No.34/2026] vide order dated 05.01.2026. 4. In view thereto, the issue raised in this peti- tion need not be again examined by this Court and the writ petition stands disposed of in the same terms as Sheela Kumari (supra). 5. We have already held that if any representation is made, the same shall be considered and examined by the authorities.” 16. He further submits that prior to issuance of notifications dated 20.11.2025 as well as 28.12.2025 proper procedure as prescribed under the Act of 1994 has been followed and the proposals sent by the Collectors and SDMs were considered by the Committee constituted by the State Government and only after considering the proposals and representations received by them, the notification dated 20.11.2025 has been issued. He further submits that the notification dated 28.12.2025 was issued in furtherance of earlier notification dated 20.11.2025 to correct the clerical errors as well as to consider the representations in a meaningful manner. He further submits that the petitioners have no legal or vested right to challenge the impugned notifications and the headquarter of village panchayat has been changed under the administrative exigency for better functioning of the gram- panchayats. He further submits that the notifications have been issued by the respondents just to conclude the process of election as directed by the Coordinate Bench of this Court and in furtherance thereto the State Government is duty bound to conclude the elections by 15.04.2026 as an undertaking in this regard has been given by them before the Hon’ble Supreme Court in the matter of Saiyam Lodha (supra) and lastly prayed for dismissal of the writ petitions. 17. We have heard counsel for the parties and perused the record. 18.
17. We have heard counsel for the parties and perused the record. 18. These writ petitions filed on behalf of the petitioners deserve to be dismissed for the reasons; firstly the issue raised by the petitioners in these writ petitions has been thoroughly considered and decided by the Coordinate Bench of this Court in the matter of Sheela Kumari (supra), wherein specific questions were framed and answered by the Co-ordinate Bench of this Court which have again been raised by the petitioners in the present writ petitions and therefore, the same require no interference; secondly the judgment passed by the Division Bench of this Court has been further upheld by the Hon’ble Supreme Court in the matter of Villagers of Revenue village Singhania and another (supra); thirdly the Hon’ble Supreme Court in the matter of Villagers of Revenue village Singhania and another (supra) has considered the fact that there is no infringement of any constitutional or legally vested right of the petitioners and on that ground the SLP was dismissed and granted liberty to the Gram Panchayat that in case of any difficulty in its management or in providing services to the village residents, the Gram Panchayats will be at liberty to approach the competent authorities to shift the headquarter; fourthly the Coordinate Bench of this Court in the matter of Ratan Lal (supra), wherein the same issue was under challenge, the said PIL petition was dismissed by the Coordinate Bench of this Court vide order dated 13.01.2026 considering the judgment in the matter of Sheela Kumari and villagers of Singhania (both supra); lastly since the matter relates to holding the elections of Gram Panchayat, Panchayat Samities and Zila Parishad which has already been delayed for about one year, we are not inclined to disturb the process of election which is under progress and the State Government has to hold the elections upto 15.04.2026 in terms of the undertaking given by them before the Hon’ble Supreme Court. 19. In view of the above, no case is made out in favour of the petitioners, hence these writ petitions stand dismissed. Copy of this order be separately placed in each connected file.