Case Note & Summary
The petitioner, Naganagouda, filed a writ petition under Article 226 of the Constitution of India challenging the order dated 30.12.2024 passed by the Assistant Commissioner, Dharwad Sub-Division, under Section 95 of the Karnataka Land Revenue Act, 1964 (KLR Act), which allowed the conversion of agricultural land to non-agricultural use. The petitioner claimed to be the owner of the land in question. However, the court noted that the petitioner had purchased the land on 20.01.2025, after the conversion order was passed. The respondents, including the Deputy Commissioner and private parties, argued that the petitioner lacked locus standi to challenge the order. The court examined the issue of maintainability and held that since the petitioner was not the owner of the land at the time of the conversion order, he had no right to challenge it. The court relied on the principle that a subsequent purchaser cannot question the validity of a conversion order passed prior to his purchase. The petition was dismissed as not maintainable, with liberty to the petitioner to pursue other remedies if available under law.
Headnote
A) Land Law - Locus Standi - Challenge to Conversion Order - Petitioner purchased land after conversion order was passed - Held that the petitioner has no locus standi to challenge the conversion order as he was not the owner at the time of conversion (Para 6).
B) Land Law - Conversion under KLR Act - Section 95 - The conversion order under Section 95 of the Karnataka Land Revenue Act, 1964 is a quasi-judicial order that can be challenged only by the person who was the owner at the time of the order or who is aggrieved by the order - Held that a subsequent purchaser cannot challenge the conversion order (Para 6).
Issue of Consideration
Whether the petitioner, who purchased the land after the conversion order was passed, has locus standi to challenge the conversion order under Section 95 of the Karnataka Land Revenue Act, 1964.
Final Decision
The writ petition is dismissed as not maintainable. The petitioner is at liberty to pursue other remedies available under law.
Law Points
- Locus standi
- Land conversion
- KLR Act
- Section 95
- Section 94
- Writ petition
- Maintainability
- Ownership at time of conversion
Case Details
2020 LawText (KAR) (09) 62
WP No. 103858 of 2025 (KLR-RES)
Naganagouda S/o Shivanagouda Neeralagi
The Deputy Commissioner, Dharwad; The Assistant Commissioner, Dharwad Sub-Division; The Tahashildar, Dharwad Taluk; Smt. Anuradha W/o Vansant Shiroor; Sri Niraj S/o Vansant Shiroor; Smt. Sonali W/o Kiran Hedge; Smt. Kamala W/o Mohan Shiroor; Sri Santosh S/o Mohan Shiroor; Smt. Anjali W/o Jagadish Kani; Sri Arjun S/o Sahadev Shiroor; Sri Krishna S/o Sadashivarao Shiroor; Sri Suhas S/o Ramadas Baljekar; Smt. Sushma W/o S. Nadakarani (Dead); Sri Sujay S/o Sudheer Nadakarni; Sri Kunal S/o Sudheer Nadakarani; Dr. Sundar S/o Lakshman Balle; Smt. Kanchana W/o Uday Nadakarani; Kumari Tanuja D/o Sundar Balle; Smt. Durgabayi W/o Mohan Nilekani; Smt. Radha W/o Gurunath Rao; Smt. Lalita W/o Umesh Kumata; Dr. Kumada W/o Telanga Shiroor; Sri Jayat S/o Annaji Shiroor; Smt. Prabha W/o Annaji Shiroor; Sri Anil S/o Mohan Shiroor
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Nature of Litigation
Writ petition under Article 226 of the Constitution of India challenging an order under Section 95 of the Karnataka Land Revenue Act, 1964.
Remedy Sought
Petitioner sought quashing of the conversion order dated 30.12.2024 passed by the Assistant Commissioner.
Filing Reason
Petitioner claimed to be the owner of the land and challenged the conversion order.
Previous Decisions
The Assistant Commissioner had passed the conversion order on 30.12.2024. The petitioner purchased the land on 20.01.2025.
Issues
Whether the petitioner has locus standi to challenge the conversion order under Section 95 of the KLR Act when he purchased the land after the order was passed.
Submissions/Arguments
Petitioner argued that he is the owner of the land and the conversion order is illegal.
Respondents argued that the petitioner lacks locus standi as he was not the owner at the time of the conversion order.
Ratio Decidendi
A person who purchases land after a conversion order under Section 95 of the Karnataka Land Revenue Act, 1964 has been passed has no locus standi to challenge that order, as he was not the owner at the time of the order and is not aggrieved by it.
Judgment Excerpts
The petitioner has purchased the property on 20.01.2025 i.e., after the order impugned was passed on 30.12.2024. Therefore, the petitioner has no locus standi to challenge the said order.
Procedural History
The Assistant Commissioner passed the conversion order on 30.12.2024. The petitioner purchased the land on 20.01.2025 and filed the writ petition on an unspecified date. The High Court heard the matter on 12.09.2025 and dismissed the petition.
Acts & Sections
- Karnataka Land Revenue Act, 1964: Section 95
