Court finds exclusion of Village Manlog Badog from Gram Panchayat Hanuman Badog manifestly arbitrary and unreasonable
In a significant ruling, the Himachal Pradesh High Court has set aside the state's notification for the reorganization of Gram Panchayats that resulted in the exclusion of Village Manlog Badog from Gram Panchayat Hanuman Badog and its inclusion in Gram Panchayat Darlaghat. The Division Bench, comprising Justices Vivek Singh Thakur and Ranjan Sharma, found the state's actions arbitrary, unreasonable, and contrary to the factual matrix on the ground.
The case was brought forward by the Nehru Yuva Club of Village Manlog-Badog and Mahila Mandal of Village Manlog-Badog, who challenged the notification dated 27 January 2026, arguing that the reorganization disregarded geographical proximity and local realities. The petitioners contended that the distance between Manlog Badog and Hanuman Badog is merely 2-3 kilometers, whereas the new Gram Panchayat Darlaghat is situated approximately 6 kilometers away.
During the proceedings, the court noted that the reorganization ignored crucial factors like geographical location, contiguity, and population considerations. The court highlighted that the population of Village Manlog Badog is around 280, while Gram Panchayat Hanuman Badog has 1,500 people and Darlaghat has approximately 4,500 residents, making the inclusion of Manlog Badog into Darlaghat unreasonable.
The High Court referred to several precedents, including judgments by the Supreme Court, which emphasize the limited judicial review in cases where actions are manifestly arbitrary or irreconcilable to constitutional values. Citing the judgments in Kishorchandra Chhhanganlal Rathod v. Union of India and Dravida Munnetra Kazhagam v. Secretary, Governor's Secretariat, the court reaffirmed its authority to intervene when necessary.
Ultimately, the court quashed the notification for reorganization and subsequent delimitation, directing the state to issue revised notifications for the constitution and delimitation of Gram Panchayats Hanuman Badog and Darlaghat within five days.
The judgment serves as a reminder of the importance of considering ground realities and local sentiments in administrative decisions, especially when grassroots governance is involved. The court also cautioned against undertaking large-scale reorganizations in haste, particularly when elections are impending, as such actions could be perceived as procrastination or a delaying tactic.
Bottom Line:
Panchayati Raj Institutions - Reorganization and delimitation of Gram Panchayats - Exclusion of Village Manlog Badog from Gram Panchayat Hanuman Badog and its inclusion in Gram Panchayat Darlaghat held manifestly arbitrary, unreasonable, and contrary to the factual matrix on the spot - Notification regarding such reorganization quashed and set aside.
Statutory provision(s): Himachal Pradesh Panchayati Raj Act, 1994 Section 3(2)
