In a significant judgment reinforcing the rule of law and administrative discipline, the Supreme Court of India has held that a State government cannot act in contravention of its own declared policy, and quashed the decision of the Rajasthan Government to name newly created revenue villages after private individuals.
A Bench comprising Justice Sanjay Kumar and Justice Alok Aradhe allowed an appeal filed by residents of Village Sohda in Barmer district, restoring the order of the Single Judge which had struck down the impugned notifications. The Supreme Court categorically ruled that the State’s action was arbitrary, illegal, and violative of its own binding policy framework.
Background of the Case
The dispute arose when the State Government of Rajasthan issued notifications under the Rajasthan Land Revenue Act, creating new revenue villages and naming them after private individuals, including local persons. This decision triggered objections from residents of Village Sohda, who challenged the notifications before the Rajasthan High Court.
The petitioners contended that the State’s action was in direct violation of its own policy, which prohibited naming villages or public institutions after private individuals. According to them, such naming was permissible only in exceptional cases and strictly in accordance with prescribed guidelines.
A Single Judge of the Rajasthan High Court accepted the challenge and quashed the notifications. However, the State Government appealed the decision, following which a Division Bench reversed the Single Judge’s ruling, prompting the villagers to approach the Supreme Court.
Issues Before the Supreme Court
The primary questions before the Supreme Court were:
- Whether the State Government could depart from its own binding policy while exercising statutory powers under the Rajasthan Land Revenue Act.
- Whether naming revenue villages after private individuals was arbitrary and violative of administrative law principles.
- Whether the Division Bench erred in interfering with the Single Judge’s well-reasoned order.
Supreme Court’s Observations
Allowing the appeal, the Supreme Court firmly held that government policy, once framed, binds the State, unless amended or withdrawn in accordance with law.
“The Government cannot act contrary to its own policy,” the Bench observed, emphasising that executive discretion is not unfettered and must operate within self-imposed limitations.
The Court noted that the Rajasthan Government had failed to demonstrate any legal justification or exceptional circumstances warranting a deviation from its established policy. The action of naming villages after individuals was therefore held to be arbitrary and unsustainable.
Binding Nature of Executive Policy
The Bench reiterated settled principles of administrative law, holding that:
- Government policies are not mere guidelines but are binding on the executive.
- Any departure from policy must be reasoned, transparent, and legally justified.
- Arbitrary deviation undermines Article 14 of the Constitution, which guarantees equality before law.
The Court held that allowing the State to act contrary to its policy would lead to uncertainty, favouritism, and erosion of public trust in governance.
Restoration of Single Judge Order
After examining the records, the Supreme Court found that the Single Judge of the Rajasthan High Court had correctly appreciated the facts and law. The Division Bench, according to the Court, erred in setting aside a reasoned decision without addressing the fundamental issue of policy violation.
Accordingly, the Supreme Court:
- Set aside the Division Bench judgment, and
- Restored the Single Judge’s order, thereby quashing the impugned notifications naming villages after individuals.
Significance of the Judgment
This ruling has wide implications for administrative governance across India, particularly in matters involving:
- Naming of public institutions, villages, and infrastructure;
- Exercise of statutory powers by State governments; and
- Adherence to executive policies.
Key takeaways include:
- Executive policies are enforceable restraints on government action.
- States cannot selectively apply or ignore policy for convenience.
- Arbitrary naming of public entities violates constitutional norms of fairness and non-arbitrariness.
- Judicial review extends to examining whether the State has adhered to its own declared standards.
Judicial Discipline and Rule of Law
The judgment reinforces that good governance is rooted in consistency and predictability. When governments formulate policies, citizens are entitled to expect that such policies will be uniformly implemented.
The Supreme Court’s ruling sends a clear message that symbolic acts like naming public places cannot be driven by political or personal considerations, and must comply with established legal and policy frameworks.
Broader Constitutional Context
The Court’s reasoning aligns with earlier precedents where it has held that executive action must be informed by reason, fairness, and transparency. Deviation from policy without justification amounts to arbitrariness, which is antithetical to constitutional governance.
By quashing the Rajasthan Government’s action, the Court reaffirmed that statutory power cannot be exercised in isolation from constitutional discipline.
Conclusion
The Supreme Court’s decision in quashing the naming of Rajasthan villages after private individuals is a significant reaffirmation of administrative accountability. It underscores that government policy is not optional, and deviation without lawful justification will invite judicial correction.
The ruling strengthens public confidence in the idea that the State itself is bound by the law it creates, and that courts will intervene to prevent misuse of executive discretion.
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