Case Details

Citation(s)
2026 SLG 942 2026 SLD 942 = 2026 LHC 2387
Lahore High Court
WRIT PETITION NO.1260 OF 2022
Presented By: (MIRZA VIQAS RAUF) JUDGE
Dates of hearing: 01.04.2026. Petitioners by: Chaudhary Umar Hayat, Advocate. Petitioners in W.P.No.977 of 2023 by: Sardar Bilal Firdous, Advocate.
Respondent No.2 by: Mr. Muhammad Zafar-ul-Hassan Joiya, Advocate. Ms. Rahat Farooq Raja, Assistant Advocate General, Punjab. Muhammad Afzal Hiraj, Tehsildar and Muhammad Uziar, Naib Tehsildar, Pindi Gheb. Muhammad Saeed Khan, Patwari Halqa Toot and Atif Mehmood Patwari Halqa Parri.

LIAQUAT ALI KHAN and others

VERSUS

SENIOR MEMBER BOARD OF REVNUE and others.

Law: Punjab Consolidation of Holdings Ordinance, 1960

Section: 3, 13

Law: Punjab Land Revenue Act, 1967

Section: 4(9), 40, 116

 SUMMARY

In this judgment by Mirza Viqas Rauf, the petitioners challenged a notification whereby ongoing consolidation proceedings in certain villages were abandoned and settlement operations were initiated instead.

The Court held that:

  • The Punjab Consolidation of Holdings Ordinance, 1960 governs consolidation proceedings.
  • There is no lawful authority to abandon such proceedings arbitrarily.
  • Even if annulment is considered, it must follow:
    • Section 13 (revision powers with hearing)
    • Rules 52 & 53 of 1998 Rules (procedure for annulment)
  • No opportunity of hearing was given → violation of natural justice (audi alteram partem).
  • Authorities wrongly relied on Punjab Land Revenue Act, 1967, causing jurisdictional overlap.

👉 Result: Notification declared illegal and set aside.

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