Abandonment, partition &

disposal of holding
Project submitted to
Ms. Sonal Das
(Faculty: Land Laws)

Project submitted by
Arindam Ghosh
Roll no.23
Semester Eighth
Submitted on 26 th February, 2014

HIDAYATULLAH NATIONAL LAW UNIVERSITY

RAIPUR, CHHATTISGARH

TABLE OF CONTENTS

Abandonment, Partition & Disposal of Holding

Acknowledgements

List of Abbreviations

Table of Cases

Scope & Objectives of Study

Research Methodology

Introduction

Chapter

8-17
Abandonment, Partition & Disposal of Holding

Conclusion & Suggestions

17

Bibliography

18

ACKNOWLEDGMENTS
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Abandonment, Partition & Disposal of Holding

At the outset, I would like to express my heartfelt gratitude and thank my teacher, Ms. Sonal
Das, for putting her trust in me and giving me a project topic such as this and for having the faith
in me to deliver. Thank you for an opportunity to help me grow.
My gratitude also goes out to the staff and administration of HNLU for the infrastructure in the
form of our library and IT Lab that was a source of great help for the completion of this project.

- Arindam Ghosh

(Semester Eighth)

List of Abbreviations
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Abandonment, Partition & Disposal of Holding

1. Art
2. All ER
3. ALJ
4. Bom
5. Cal
6. Co
7. DB
8. Del
9. Ed.
10. FB
11. F 2d
12. HC
13. RN
14. SCC
15. Sec
16. v.
17. Vol.

Article
All England law Reports
Allahabad Law Journal
Bombay
Calcutta
Company
Division Bench
Delhi
Edition
Full Bench
Federal Reports 2nd Circuit
High Court
Revenue Notes
Supreme Court Cases
Section
Versus
Volume

Table of Cases
1. Alladin v. State of M.P 1992 RN 345 (HC).
2. Bahadursingh v. Siddanath 2001 RN 95.
3. Belabai v. Dharamkumar. 1993 RN 65 (HC).
4. Gafoorkhan v. Bhulibai.. 1993 RN 431 (HC).
5. Gangaram v. Kanhaiyalal 1971 RN 475 (HC) (DB).
6. Gappulal v. Gajanand.. 2001 RN 136.
7. Gulab v. Mangilal 1992 RN 341 (HC).
8. Kesharsingh v. Premkunwarbai 1992 RN 323 (HC).
9. Manbodh v. Kamlabai.. 1987 RN 125.
10.
Nagjiram v. Mangilal 1976
RN 261.
11.
Narendraprasad v. Sukhrani 2000
RN 178.

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Abandonment, Partition & Disposal of Holding

12.

Narendrasingh v. Ranjit 1995 RN 230

(Revenue).
13. Nat'l Comics Publications v. Fawcett Publications. 198 F.2d 927 (2d Cir. 1952).
14.
Paitram v. Board of Revenue.. 1968 RN 158
(HC) (DB).
15.
Prasad v. Smt. Deeson .2000
RN 174.
16.
Radhemohan v. Omnarayan 1991 RN
87 (HC).
17.
Rewa Prasad v. Amsa Bai.. 1976
RN 31.
18.
Umrao Singh v. Gopichand. 1987
RN 412.

SCOPE & OBJECTIVES OF STUDY

The scope of this topic is to study about the abandonment, partition and disposal of holdings
under the Chhattisgarh Land Revenue Code. The objective of the study is as follows:
To study and analyse about abandonment, partition and disposal of holdings under the

Chhattisgarh Land Revenue Code.

RESEARCH METHODOLOGY
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Abandonment, Partition & Disposal of Holding

The scope of this topic is to study about the abandonment, partition and disposal of holdings
under the Chhattisgarh Land Revenue Code.
This research is doctrinal in nature. Both, secondary and primary resources have been largely
used to gather information and data about the topic. Secondary resources include the
commentaries on the Chhattisgarh Land Revenue Code, 1959 while primary resources include
the actual act and its bare provisions.
Books and other reference as guided by Faculty of Land Laws have been primarily helpful in
giving this project a firm structure. Websites, dictionaries and articles have also been referred.
Footnotes have been provided wherever needed, to acknowledge the source.

INTRODUCTION
In

law,

abandonment

is

the

relinquishment

or

renunciation

of

an interest, claim, privilege, possession, or right, especially with the intent of never again
resuming or reasserting it. Such intentional action may take the form of discontinuance or
a waiver. This broad meaning has a number of applications in different branches of law.
Common law abandonment is "the relinquishment of a right [in property] by the owner thereof
without any regard to future possession by himself or any other person, and with the intention to

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Abandonment, Partition & Disposal of Holding

forsake [sic] or desert the right...."1 or "the voluntary relinquishment of a thing by its owner with
the intention of terminating his ownership, and without [the intention of] vesting ownership in
any other person; the giving up of a thing absolutely, without reference to any particular person
or purpose...."2
A partition is a term used in the law of real property to describe an act, by a court order or
otherwise, to divide up a concurrent estate into separate portions representing the proportionate
interests of the tenants. Under the common law, any tenant who owns an undivided concurrent
interest in land can seek such a division. In some cases, the parties agree to a specific division of
the land; if they are unable to do so, the court will determine an appropriate division. A sole
owner, or several owners, of a piece of land may partition its/their land by entering a Deed
poll (sometimes referred to as "carving out").3
Disposal means a transfer of title in the goods to any other person. The expression dispose
means to transfer or alienate. It was formerly an essential word in any conveyance of land. It
requires goods in question should be transferred to some other person in all the ways permitted
under law including sale.4

Abandonment, Partition & Disposal of Holding

Section 176 - Abandonment of holding

1 1 Corpus Juris Secundum Abandonment 2 (1985).

2 Nat'l Comics Publ'n v. Fawcett Publications, 191 F.2d 594, 598 (2d Cir. 1951) supplemented sub nom. Nat'l
Comics Publications v. Fawcett Publications, 198 F.2d 927 (2d Cir. 1952).

3 Oxford Law Dictionary, 4th ed., 2006.

4 Blacks Law Dictionary, 2nd ed., 2008.
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(1) If a bhumiswami ceases to cultivate his holding for two years either by himself or by some
other person, does not pay land revenue and has left the village in which he usually resides,
the [Tahsildar]5 may, after such enquiry as he may deem necessary, take possession of the land
comprising the holding and arrange for its cultivation by letting it out on behalf of the
bhumiswami for a period of one agricultural year at a time.
(2) Where the bhumiswami or any other person lawfully entitled to the claims it within a period
of three years from the commencement of the agricultural year next following the date on which
the [Tahsildar] took possession of the land, it shall be restored to him on payment of the dues, if
any, and on such terms and conditions as the [Tahsildar]6 may think fit.
(3) Where no claim is preferred under sub-section (2) or if a claim is preferred and disallowed,
the [Tahsildar]7 shall make an order declaring the holding abandoned and the holding shall vest
absolutely in the State Government, from such date as may be specified in that behalf in the
order.
(4) Where a holding is declared abandoned under sub-section (3), the liability of the bhumiswami
for the arrears of revenue due from him in respect thereof shall stand discharged.
Applicability The following conditions must exist so as to attract applicability of the
provision:
1. That the bhumiswami has ceased to cultivate his holding for two years either by himself
or by some other person;
2. That he has not paid the land revenue;
3. That he has left the village of his usual residence.
All these three conditions should exist together. The existence of one or two would not attract the
provision and shall not confer the Tahsildar with a jurisdiction to initiate the proceedings under

5 Substituted by M.P. Act No. 24 of 1961 (w.e.f. 23.6.1961).

6 Substituted by M.P. Act No. 24 of 1961 (w.e.f. 23.6.1961).
7 Substituted by M.P. Act No. 24 of 1961 (w.e.f. 23.6.1961).
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Abandonment, Partition & Disposal of Holding

this section.8 Land not cultivated and other conditions of non-payment of land revenue and
leaving place of ordinary residence must be pleaded and proved.9 Proceeding for abandonment of
holding may be started when bhumiswami not available.10
Object The object behind enactment of this section appears to be twofold:
1. Productivity.
2. Accountability. The land allotted by the state to a bhumiswami should not remain uncultivated
nor the land revenue should fall in arrears and thereby cause national loss.11
Meaning The possession of one co-owner is normally treated to be possession of all coowners, unless necessary factors are asserted and proved. Absence for some duration does not
necessarily lead to position of abandonment. The expression means:
1. Consciousness of rights.
2. Intentional giving up of those rights in a manner to give rise to complete demolition of
those rights.12
The provisions contained in section 176 have the effect of depriving a bhumiswami of his vested
rights in a holding and hence to be strictly construed. The declaration of abandonment of holding
and its vesting in the state are the stages contemplated by sub-section 3 and not sub-section 1.13
Mandatory Procedure The mandatory procedure consists of the following steps:

8 Alladin v. State of M.P. 1992 RN 345.

9 Abdul Karim v. Hafif Mohd. 1997 RN 381 (HC).
10 Manbodh v. Kamlabai 1987 RN 125.
11 Alladin v. State of M.P. 1992 RN 345 (HC).
12 Gafoorkhan v. Bhulibai 1993 RN 431 (HC).
13 Alladin v. State of M.P. 1992 RN 345 (HC).
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1. The Tahsildar having formed a prima face opinion about the conditions under this
section, he had to hold such enquiry as he may deem necessary for the for the purpose of
reaffirming his opinion.
2. The Tahsildar than shall take position of the land.
3. The Tahsildar has to arrange for the cultivation by letting it out on behalf of the
bhumiswami for a period of three years, but through lease for one agricultural year at a
time.
4. The bhumiswami or any other person lawfully entitled to the land may put forth his claim
within a period of 3 years calculated from the date referred to in sub-section 2.
5. If such claim satisfied the terms and conditions contemplated by sub-rules 1 to 4 of rule
2, the land has to be restored.
6. It is only when no claim is preferred under sub-section 2 and disallowed and the period of
3 years has expired that the Tahsildar shall acquire jurisdiction to make an order declaring
the holding abandoned.14
Under section 176 only that land can be taken possession of about which the following three
factors are proved:
1. That the bhumiswami has ceased to cultivate his holding for two years either by himself
or by some other person;
2. That he has not paid the land revenue;
3. That he has left the village of his usual residence.
These facts should be determined after noticing the bhumiswami in the prescribed manner. Any
further steps taken without such enquiry are void.15
Rules - 1. In these rules16,(a) "Code" means the Chhattisgarh Land Revenue Code, 1959 (No. 20 of 1959);
(b) "Section" means a section of the Code.

14 Alladin v. State of M.P. 1992 RN 345 (HC).

15 1987 RN 190.
16 Vide Notification No. 338-CR-532-VII-N-(Rules), dated 11.1.1960.
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2. When a bhumiswami or any other person entitled to the abandoned land claims it under subsection (2) of Section 176 of the Code, the land shall be restored to him subject to the following
terms and conditions, namely :(1) That he has paid before a specified date, the arrears of land revenue and other outstanding
dues, if any, in respect of the holdings;
Explanation.-Amount or amounts received from person or persons to whom the land was let out
under sub-section (1) of Section 176 shall be set-off against the arrears of land revenue;
(2) That he shall not disturb the possession of the person to whom the land was let out by
the [Tahsildar]17 under sub-section (1) of Section 176 and shall allow him to tend, reap and
remove crop standing on the date of the order of restoration;
(3) That he shall take possession of the land from the commencement of the agriculture year next
following the date of order; and
(4) That he agrees to cultivate the land personally and to reside in the village which the
bhumiswami had left.
Section 177 - Disposal of holdings
(1) If a bhumiswami whose land has been assessed for the purpose of agriculture under section
59, or who holds lands for dwelling purposes, dies, without known heirs, the Tahsildar shall take
possession of his land and may lease it for a period of one year at a time.
(2) If within three years of the date on which the Tahsildar takes possession of the land any
claimant applies for the holding being restored to him, the Tahsildar may, after such enquiry as
he thinks fit, place such claimant in possession of the land or reject his claim.
(3) The order of the Tahsildar passed under sub-section (2) shall not be subject to appeal or
revision but any person whose claim is rejected under sub-section (2) may, within one year from
the date of the communication of the order of the Tahsildar file a civil suit to establish his title,

17 Substituted by Notification No. 492-3447-VII-N-1, dated 2.2.1966.

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and if such suit is filed, the Tahsildar shall continue to lease out the land as provided in subsection (1).
(4) If no claimant appears within three years from the date on which the [Tahsildar] 18 took
possession of the land or if a claimant whose claim have been rejected under sub section (2)
does not file a suit within one year as provided in sub-section (3), the [Tahsildar] may sell the
deceased bhumiswamis right in the holding by auction.
(5) Notwithstanding anything contained in any law for the time being in force a claimant who
establishes his title in land which has been dealt in accordance with the provisions of this section,
shall be entitled only to the rents payable under sub-section (1) and the sale proceeds realized
under sub-section (4) less all sums due on the holding account of land revenue and the expenses
of management and sale.
General In all proceedings under section 177 of the code, there would be two parties whose
interest calls for protection. One party is the person, if any, ultimately recognised as the lawful
heir of or the person entitled to succeed the deceased bhumiswami. The second party is the state,
if it is found that there is no person who can recognised as the lawful heir.
The protection that either of the parties require is regarding maintenance of the property in
dispute in the condition in which it was and regarding profits. The act of the state taking
possession of the land in dispute and leasing it out for short periods is, in substance, the act of
placing the property in custodia legis so that the protection as aforesaid may be ensured.19
Rights of co-owner land owned by joint owners. One of them died issueless but no action was
taken under section 177 of the code. The other co-owner has a right to file suit for eviction
against a trespasser.20
Section 178 - Partition of holding
18 Subs. By M.P. Act No. 24 of 1961 (w.e.f. 23-6-1961).
19 Awtar Singh v. Ram Singh 1974 RN 231.
20 Belabai v. Dharamkumar 1993 RN 65 (HC).
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(1) If in any holding, which has been assessed for purpose of agriculture under Section 59, there
are more than one bhumiswami any such bhumiswami may apply to a Tahsildar for a partition of
his share in the holding:
[Provided that if any question of title is raised the Tahsildar shall stay the proceeding before him
for a period of three months to facilitate the institution of a civil suit for determination of the
question of title.]21
[(1-A) If a civil suit is filed within the period specified in the proviso to sub-section (1), and stay
order is obtained from the Civil Court, the Tahsildar shall stay his proceedings pending the
decision of the Civil Court. If no civil suit is filed within the said period, he shall vacate the stay
order and proceed to partition the holding in accordance with the entries in the record of rights.]22
(2) The Tahsildar, may, after hearing the co-tenure holders, divide the holding and apportion the
assessment of the holding in accordance with the rules made under this Code.
[(3), (4), (5) & Explanation II]23
Explanation I.-For purposes of this section any co-sharer of the holding of a bhumiswami who
has obtained a declaration of his title in such holding from a competent Civil Court shall be
deemed to be a co-tenure holder of such holding.
General Interpretation It includes:
1. The holding should belong to more than one bhumiswami.
2. There should be an application for partition to the Tahsildar.
3. There is a question of title and the Tahsildar should stay the proceeding for a period of 3
months to institute a civil suit.
4. Where no suit is filed within the time allowed, the Tahsildar shall vacate the stay and
proceed with the partition.

21 Substituted by M.P. Act No. 18 of 1978 (w.e.f. 13.6.1978).

22 Inserted by M.P. Act No. 18 of 1978 (w.e.f. 13.6.1978).
23 Omitted by M.P. Act No. 25 of 1964 (w.e.f. 23.4.1964).
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Abandonment, Partition & Disposal of Holding

5. The Tahsildar shall make the partition of holding and apportion the land revenue
assessment.
Applicability & Scope Partition should be made upto their share and not of the other shareholders who have not so applied.24A lady bhumiswami can claim partition. Tenancy law and not
the personal law will govern the claim. 25Question of title can be decided by civil court only.
Actual partition can be effected by revenue court under the provision of this code. 26 The scheme
of section 178 envisages that partition can be asked by a co-sharer of any holding which has been
assessed for purposes of agriculture under section 59.
Right to apply and application for partition Proceedings can be initiated on application only.
Order of partition cannot be made on mutation register. Proclamation should be made in the
manner provided under rule 17.27
Dispute about title question of title is raised within the meaning of the proviso to sub-section
1 when the applicants right to partition is disputed. The proviso comes into play both when the
question of title is genuine or bogus. The second requirement of the proviso is that the revenue
authorities have just to stay their hands as if they will literally shut up the case to be re-opened
when the question of title has been decided by a civil suit. When the right to claim a partition is
disputed, a question of title arises. The party seeking to disturb the status quo should be directed
to approach the civil court for decision of the dispute.28
Stay of Proceedings Where a question of title is raised by the non-applicant in a case for
partition of holding, the revenue court should not dismiss the application for partition but should
adjourn the hearing of the said application for a reasonable time directing the person raising the
24 Narendrasingh v. Ranjit 1995 RN 230 (Revenue).
25 Kesharsingh v. Premkunwarbai 1992 RN 323 (HC).
26 Gulab v. Mangilal 1992 RN 341 (HC).
27 Mangilal v. Gopalkrishna 1994 RN 265 (Revenue).
28 Rewa Prasad v. Amsa Bai 1976 RN 31.
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question of title to institute a civil suit within certain time that may be fixed for having the title
adjudicated.29 A party who wants change in the status quo should get the question of title decided
from the civil court. It is a question of form whether the application before the Tahsildar is kept
pending or dismissed. In either event proceedings can be taken up after the dispute is decided by
the civil court.30
Vacation of stay order Stay order is granted by the Tahsildar for the purpose of filing a civil
suit and obtaining stay from the civil court. Where a party in whose favour such a stay order was
granted fails to file such a suit within the time allowed, the Tahsildar shall have no option but to
vacate the stay granted by him and proceed with the proceedings of partition.
Partition by Tahsildar In partition proceedings, where co-bhumiswamis specify the lands to
be allotted to each one of them it should be respected. If any bhumiswami claims any land to be
his own, the matter should be inquired into and each bhumiswami should be given opportunity of
hearing.31 Ex parte order of partition can be challenged in civil court. 32 Partition suit is
maintainable where previous partition is not proved conclusively and the record shows holding
to be joint.33 The section indicates that the authority may partition the property on the application
of the party or on the direction of the civil court, but there is no exclusive jurisdiction of the
authority.
Apportionment of assessment The Tahsildar shall divide the liability between the persons
amongst whom the holding is so divided.

29 Paitram v. Board of Revenue 1968 RN 158 (HC) (DB).

30 Gangaram v. Kanhaiyalal 1971 RN 475 (HC) (DB).
31 Kanhaiya v. Lilabai 2001 RN 205.
32 Gappulal v. Gajanand 2001 RN 136.
33 Prasad v. Smt. Deeson 2000 RN 174.
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Jurisdiction of Civil court Civil court for declaration of title not barred but actual partition
will be made by revenue court.34 Civil court can pass only preliminary decree and declare the
rights of the parties but the actual execution has to be effected by the revenue court and not by
civil court.35
Joint Holding A joint holder can transfer his share of holding and the purchaser can claim
partition and mutation accordingly. He cannot claim partition and mutation on specific survey
numbers.36 Any joint holder can apply for partition. Where question of title is raised, time of
three months should be allowed for bringing stay order from civil court.
Appeal & Revision Any partition which takes place under this section cannot be varied or
reversed under section 170. In the context of a joint holding held by a person belonging to
notified scheduled tribe and a person not belonging to such a scheduled tribe, the only remedy
available under the law to vary or reverse the order passed under section 178 in either way of
appeal under section 44 or in revision under section 50 of this code.37
Rules - 1.

(1) An application by a co-tenure-holder for partition of his share in the holding

under sub-section (1) of Section 178 of the Chhattisgarh Land Revenue Code, 1959, shall contain
the following particulars :(a) The area of each field constituting the holding and numbers borne by each of them in the
village Jamabandi or Record-of-Rights;
(b) The land revenue of the holding and the right in which it is held;
(c) The names of the co-tenure-holders and the extent of their shares.

34 Radhemohan v. Omnarayan 1991 RN 87 (HC).

35 Umrao Singh v. Gopichand 1987 RN 412.
36 Cheble v. Kamla 1994 RN 175.
37 Hiralal v. Bhoja 1983 RN 44.
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(2) The application shall be accompanied by a copy of entries in the latest Jamabandi or Recordof-Rights.
2. On receipt of the application the Tahsildar shall hear the applicant in person and if after
hearing the applicant it appears to him that the case does not fall under sub-section (3) of Section
178, he shall cause to be served in accordance with the provisions of Rules 11 to 16 in the First
Schedule to the said Code, notices in Form A appended to these rules on the co-tenure-holders
requiring them to appear before him and state their objections, if any, on a day to be specified in
the notice, which shall not be less than thirty or more than sixty days from the date of issue of the
notices. He shall also cause a proclamation in Form B appended to these rules to be published in
accordance with the provisions of Rule 17 in the First Schedule to the said Code stating his
intention to partition the holding.
3. If, after hearing the applicant, co-tenure-holders and any other persons appear, it appears to the
Tahsildar, that there is sufficient reason for disallowing the partition, he shall, by order in writing,
reject the application.
4. If the Tahsildar does not reject the application, he shall proceed, after determination and
recovering from the applicant the costs of making partition, to effect the partition either
personally or through such agency as he may appoint. So far as practicable, whole survey
numbers/plot numbers shall be allotted and recourse to sub-division should be taken only in rare
cases. So far as possible compact areas of land should be allotted to each party and care should
be taken to ensure that the productivity of the area allotted to each party is in proportion to his
share in the holding. Such productivity should be determined on the basis of the variety of the
soils in the holding and their present condition.38
5. The assessment of the holding shall be distributed in proportion to the shares hold in the
holding by the various co-tenure-holders. While apportioning the assessment, the fractions of a
Naya Paisa shall be ignored.
6. After the partition has been completed, the Tahsildar shall hear any objections which the
parties may make, and shall either amend or confirm the partition. The partition shall take effect
38 Vide Notification No. 199-6477-VII-N (Rules), dated 6.1.1960.
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from the commencement of the agricultural year next following the date of such amendment or
confirmation.
7. In case the interest of one co-tenure-holder is to be sold to another co-tenure holder willing to
purchase it, the price of the interest to be sold shall be determined in accordance with the
following principles:(1) If a price agreed between the parties, such price should be accepted if it appears have been
arrived at bona fide.
(2) If no price is agreed upon and accepted it shall be determined and fixed having regard to(a) The rates on which similar land in the village or in its neighborhood were sold during the last
three years;
(b) Results of enquiries into the value of land, if maintained under sub-section (1) of Section 63
of the Code in the neighborhood.
(c) if no sales have taken place in the village or in its neighborhood or if there is no record results
of enquiries under clause (b) the price may be determined as far as possible, in accordance with
the provisions of the Land Acquisition Act, 1894, ignoring the extra 15 per cent for compulsory
acquisition.39
Conclusion & Suggestion -

Therefore, we can see the different provisions relating to the

abandonment, partition & disposal of holding under the Chhattisgarh land revenue code. These
rules and the provisions should be followed as strictly as possible by both the revenue authorities
as well as the bhumiswamis. It is only then that the proper working of the code can be ensured
and thus all these matters related to holdings can be smoothly carried out.

BIBLIOGRAPHY
Statutes:
1. Chhattisgarh Land Revenue Code, 1959.
39 Vide Notification No. 199-6477-VII-N (Rules), dated 6.1.1960.
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Books:
1. M.L. Jindal, M.P.& Chhattisgarh Land Revenue Code, 1959, Rajkamal Publications, (6th
ed., 2006)
2. S.K.Awasthi, M.P. & Chhattisgarh Land Revenue Code, 1959, India Publishing House,
(13th ed., 2013).
Articles:
1. Sri Sairam Sanath Kumar, Dr. V. Krishna Ananth, The Land Revenue System in M.P. &
C.G., M.P.& C.G.Land Laws Journal, Vol. II, 2008.

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