Disclaimer: This has been reported after the availability of the order of the Court and not on media reports so as to give an accurate report to our readers.
Madhya Pradesh High Court: In a public interest litigation (PIL) filed by Medha Patkar seeking registration of plots allotted to affected persons in the Narmada Dam Project, the Division Bench of Vijay Kumar Shukla and Alok Awasthi, JJ., directed the Additional Chief Secretary, Government of Madhya Pradesh, to address the issues and suggestions raised by Medha Patkar before him, and to meet her again if necessary.
Background
In 2024, a PIL was filed by Medha Patkar, a famous Social Activist, on behalf of those people who were displaced by the construction of the Sardar Sarovar Dam (Narmada Dam) seeking directions to the State to complete the registration of the houses plots allotted to them in a time-bound manner without levying registration cost and stamp duty as per the Rehabilitation and Resettlement Policy for Narmada Project.
Medha Patkar also filed several allotment letters issued to the affected persons in 2002 by the Rehabilitation Officer, Sardar Sarovar Project of the Districts Dhar, Badwani, Khargone, and Alirajpur. These allotment letters had never been registered under the Registration Act, 1908, and the Stamp Act, 1899, to give a complete title to them. She contended that the State had not formulated any policy regarding how the allotment certificates would be treated as title documents. In the absence of registration, the allotment certificates cannot be used to take a loan or sell/mutate/demarcate the plot. Furthermore, there were no boundaries or development plans to show the exact location of the plots; the allotment certificates only mentioned the area and plot numbers.
Proceedings and Subsequent Developments
On 25 September 2025, the Court noted that the lack of registration could lead to several litigations. Accordingly, the Court directed the Additional Chief Secretary to propose how the allotment certificates could be registered.
In compliance with the 25 September order, the Additional Chief Secretary admitted that land allotment letters issued to the affected persons had not been registered by the registering authority to date. He also submitted that the State Government had made a comprehensive plan of survey of the entire State for the purpose of demarcation, registration, mutation, etc. In the survey, the case of these affected persons would be considered on a priority basis.
However, unimpressed by such a proposal, the Court, vide order dated 14 October 2025, issued the following directions:
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The Collectors of all 4 aforementioned districts shall constitute committees comprising the Sub-Divisional Officer, Tahsildar, and Sub-Registrar (Stamps). The Committee shall register the sale deeds in favour of lands’ oustees or in the names of legal heirs, mutate their names in the revenue records, and correct the revenue map within 2 months. Thereafter, the local body concerned, Panchayat or Municipality, shall enter the names in its record.
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The Narmada Valley Development Authority and Narmada Control Authority shall authorise a competent officer, who shall be a member of the Committees constituted by the Collector.
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The land shall be properly identified on a priority basis by organising a camp in the district headquarters.
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Medha Patkar shall coordinate between these land oustees and the Committees for effective and speedy compliance with the aforesaid directions.
The Court further directed that it shall be the primary responsibility of the Additional Chief Secretary to ensure compliance with these directions.
Accordingly, a compliance report was filed by the authorities informing that the Committee had been formed and the State had taken actions regarding high-level coordination, free of cost registration, etc. Furthermore, registration camps had been organised in 2 tehsils, and absentee plot holders were summoned. However, the State sought time for the land survey.
Thereafter, a progress report was filed by the authorities, stating that the Standard Operating Procedure (SOP) for free registration had been framed and registration work had commenced. However, the State contended that registration would take 6 months.
In the order dated 17 February 2026, the Court remarked that the matter had not been taken up promptly as expected, as framing the SOP took 2 months, and the registration exercise is proposed to take 6 months. Accordingly, the Court directed the Additional Chief Secretary to appear virtually and inform why the registration and survey exercises were progressing slowly.
On the next date, Medha Patkar contended that the SOP was very lengthy and would take a long time. Additionally, there was a lack of staff. The State contended that out of 25.602 beneficiaries, applications were received only from 4119 beneficiaries. Furthermore, the Additional Chief Secretary welcomed recommendations from Medha Patkar for the SOP, if any.
Thus, vide order dated 26 February 2026, the Court directed the Additional Chief Secretary to hold a meeting with Medha Patkar within 15 days, and she was directed to submit her suggestions for the SOP and other issues. The Court further directed all the Collectors to complete registration for the 4119 applicants, and the State shall file a status report.
In compliance thereof, the State filed a status report providing a district-wise status of the registration process with a total of 2095 completed registrations across 7 tehsils. However, the report mentioned some hurdles in the registration process, such as seasonal migration of displaced persons for livelihood and the lack of consensus among legal heirs in cases involving deceased allottees. Despite these challenges, the Land Acquisition Officers (LAOs) were conducting field camps to facilitate on-the-spot verification and registration.
Medha Patkar contended that there were other issues, such as many beneficiaries not being given plots, instances of fraud and cheating, and fraudulent documentation. Furthermore, some beneficiaries were compelled to stay in the tin shades or in the government buildings, without basic amenities and facilities, as a home building grant was not being given. She also contended that she appeared before the Additional Chief Secretary and submitted her suggestions, including regarding the backwater displacement issue, but the same had not been addressed so far.
Decision
Noting the contentions, the Court directed the Additional Chief Secretary to address the issues and suggestions raised before him by Medha Patkar and meet her again, if necessary. The Court further directed the State to file the latest status report by the next date.
The matter was listed for 29 June 2026.
[Medha Patkar v. State of M.P., WP No. 35006 of 2024, decided on 28-4-2026]
Advocates who appeared in this case:
For the petitioner: Medha Patkar – Petitioner in person.
For the respondent: Sudeep Bhargava – Dy.A.G, Kushal Goyal