Restoring the Right to Register: The Fight Against Section 22-A

From Section 22-A to Land Justice

A Wake-up Call for the Two Telugu States

Land is not merely soil, nor merely a commodity. It is title, inheritance, livelihood, economic security and, in much of India, the material foundation of social stability. A defective entry can immobilise an asset for years; a defective system can turn individual hardship into institutional injustice. The controversy surrounding land records in Telangana must therefore be viewed not merely as another political dispute, but as a test of the State’s capacity to maintain an accurate, transparent and legally defensible record of land rights.

Public discourse has witnessed competing claims of large-scale irregularities involving extensive acreage, numerous transactions and financial consequences running into thousands of crores. The figure of ₹1 lakh crore has also entered the debate. Such a figure, however grave, cannot become an established fact through repetition. It requires documentary, legal and forensic verification — survey number by survey number, subdivision by subdivision, transaction by transaction.

The decisive questions are elementary: What was the original title? How was the land classified? When did the classification change? Who authorised it? Under what law? On the strength of which document? Was notice given? Was an opportunity of hearing afforded? Who acquired the property thereafter? Who ultimately benefited?

An allegation is not evidence; evidence acquires authority only when the record sustains it.

This distinction is particularly important in the debate surrounding Section 22-A of the Registration Act, 1908. The provision serves an essential public purpose by restricting registration of specified categories of protected property. Government land, assigned land and other legally protected properties cannot be left vulnerable to unauthorised alienation. The State has a duty to protect them.

But a statutory safeguard cannot become an administrative impediment to lawful ownership.

The wrongful removal of protected government land from a prohibited list is serious. Equally serious, though different in character, is the wrongful inclusion of legitimate private property in such a list. An owner may thereby be prevented from selling, mortgaging, registering, developing or otherwise enjoying property that he lawfully holds.

The governing principle should therefore be unambiguous:

What is entered must be entered transparently; what is removed must be removed with equal transparency.

The Bhu Bharati system provides mechanisms for grievances concerning properties included in the prohibited list and for correction of land records. It also recognises the problem of cases in which only a portion of a survey number was acquired by the Government but the entire survey number came to be treated as acquired. Verification, correction of the acquired extent and appropriate survey splitting are therefore not merely technical exercises; they are instruments of substantive fairness.

This is why precision is not a clerical luxury; it is a condition of justice.

Section 22-A should remain a shield for protected public interests, not become a mechanism by which lawful private rights are indefinitely immobilised.

The Survey Number and the Story It Carries

A survey number is not merely an entry in a revenue register. It is the administrative identity of a parcel and the repository of its legal history. Settlement records, revenue registers, pattadar records, registered instruments, mutations, inheritance transfers, acquisition proceedings, court orders, survey maps and changes in land use may all converge upon the same parcel. A single survey number may contain different legal interests within the same physical extent. The future of land administration must therefore move towards subdivision-wise, extent-wise, boundary-wise and geographically authenticated records, supported by a continuous documentary history.

An independent examiner should be able to reconstruct the history of a parcel without relying upon oral explanations or institutional memory. What was the original entry? When was it altered? Who authorised the alteration? Under what law? What evidence supported it? Was the affected party heard? What happened thereafter?

A land record that cannot answer these questions is an incomplete instrument of governance.

Dharani, Bhu Bharati and the Limits of Digitisation

The transition from Dharani to Bhu Bharati has generated legitimate public expectations. But changing a digital platform is not, by itself, land reform. The Telangana Bhu Bharati (Record of Rights in Land) Act, 2025 provides the statutory framework for the present system. Its real test, however, lies not in the sophistication of the portal but in the reliability of the record it contains. If an erroneous record is digitised, it does not become a correct record; it merely becomes a digitised error. Every substantive alteration should therefore leave an immutable audit trail: what existed before, what replaced it, which document authorised the change, which authority approved it and when the alteration occurred.

Revenue and Registration records should, wherever relevant, be capable of reconciliation with Survey, Municipal, Forest and Endowments records. Digital technology should make manipulation more difficult and accountability more certain.

The State has acknowledged problems associated with Section 22-A and has initiated institutional measures to examine and resolve pending cases. A State-level committee has now been constituted to address properties included in the prohibitory list under Section 22-A. (The New Indian Express⁠)

Such intervention is necessary. But the disposal of accumulated cases must not be mistaken for structural reform. The enduring objective must be to make erroneous classification difficult, unauthorised alteration traceable and legitimate correction accessible.

From a Figure to an Evidentiary Finding

The alleged ₹1 lakh crore irregularity requires methodology rather than rhetoric.

Every questionable transaction should first be classified. Was it a clerical mistake, a genuine title dispute, an erroneous mutation, administrative negligence, an unlawful registration, a forged document, an encroachment, a deliberate reclassification, an abuse of authority or a criminal conspiracy?

These categories cannot be casually collapsed into one another.

To call every error corruption would be unjust. To call deliberate manipulation a clerical error would be equally dangerous.

The investigation must therefore reconstruct the entire land-record chain.

The original record should be compared with subsequent mutations. Revenue records should be reconciled with registration documents. Survey maps should be compared with physical boundaries. Acquisition proceedings should be matched against the actual extent acquired. Land-use changes should be chronologically mapped. Consideration paid should, where appropriate, be compared with contemporaneous market evidence.

The objective should be neither sensationalism nor exoneration, but evidentiary accuracy.

Follow the Record — and Follow the Money

A land inquiry should not end with the survey number.

If classification changed, what followed?

In whose name was the property transferred?

At what consideration?

Was it subsequently conveyed?

Through whom?

To whom?

And who ultimately derived the economic benefit?

Follow the record — and follow the money.

The documentary trail establishes the sequence of administrative events. The financial trail may establish the economic consequence. Their convergence can reveal whether an irregularity was merely administrative, commercially motivated or potentially criminal.

This is particularly important where land values have multiplied dramatically.

When Land Values Multiply, Accountability Must Multiply With Them

The rapid urbanisation of Hyderabad and its surrounding areas has transformed the economic significance of land classification. An alteration that once appeared administratively minor can now have consequences worth crores of rupees.

Claims of extraordinary valuations, including the figure of ₹147 crore an acre in the Diamond Jubilee area, should therefore be independently established before being treated as authenticated market fact.

But valuation is only one element.

The more consequential questions concern the original classification, land-use history, subsequent changes, adjoining parcels, approvals, transfers and ultimate beneficiaries.

The principle is universal:

The greater the discretionary power, the greater must be the corresponding accountability.

Keesara: An Illustration, Not a Generalisation

The Keesara episodes should not be made to carry a burden they cannot legitimately bear. They are not proof of the larger land controversy. At most, they illustrate why consequential official discretion requires effective institutional oversight. In 2020, former Keesara tahsildar Erva Balaraju Nagaraju was arrested by the Anti-Corruption Bureau in an alleged ₹1.10 crore bribery case relating to a land dispute. Contemporary records reported that he was accused of demanding a larger amount in connection with pattadar passbooks for disputed land. He was subsequently found hanging inside Chanchalguda Central Prison while in judicial remand, and police registered a suspicious-death case. (The New Indian Express⁠)

In September 2026, the ACB arrested Keesara Sub-Inspector Dyapa Gnanender Reddy in an alleged ₹5 lakh bribery case. According to the agency’s account, the money was allegedly accepted on the instructions of Keesara Inspector and Station House Officer Arkapally Anjaneyulu in connection with station bail and alleged favourable treatment in a police case. Both officers were produced before the competent court, and the matter remains under investigation. (The New Indian Express⁠)

These incidents should not be converted into proof of a wider land-mafia conspiracy. Their narrower institutional lesson is sufficient:

Where official discretion is substantial, supervision, auditability and accountability must be equally substantial.

A Common Land-Governance Problem

The land question cannot be confined to Telangana.

Andhra Pradesh and Telangana share a complicated historical inheritance of settlement records, revenue registers, assigned lands, forest boundaries, endowment properties, acquisition proceedings, agricultural conversion, urban expansion and prolonged litigation.

The economic transformation of the two States has, however, proceeded faster than the institutional evolution of some land records.

Villages become towns.

Agricultural land becomes urban real estate.

Land values multiply.

Administrative classifications acquire enormous financial significance.

The gap between the physical transformation of land and the administrative evolution of its records is where uncertainty, litigation and manipulation can flourish.

The challenge is therefore common to the two Telugu States.

It should be addressed as a question of governance rather than reduced to competing political narratives.

An Architecture of Land-Record Integrity

What is required is not another temporary correction drive but a permanent institutional architecture. Every survey number and subdivision should possess a complete historical record. Every Section 22-A inclusion or deletion should be supported by a reasoned order. Every material digital alteration should carry an immutable record of the officer, date, time, supporting document and approving authority. Revenue, Registration, Survey, Municipal, Forest and Endowments records should be capable of systematic cross-verification wherever their jurisdictions overlap.

High-value transactions, unusual mutations, rapid successive transfers and abrupt changes in classification should attract risk-based scrutiny.

Citizens should have access to time-bound and reasoned grievance redressal.

Where a conflict of interest exists, independent review should be mandatory.

Periodic audits should look beyond individual transactions to identify patterns — recurring beneficiaries, common intermediaries, clusters of mutations, sudden reclassification and concentrations of high-value transfers.

Inquiries must be document-centred, not personality-centred.

Governments change. Officers change. Portals change. Administrative systems change.

The evidentiary standard must not.

Protecting Public Land and Private Title

The State has a dual obligation.

It must protect public land from encroachment, fraudulent alienation and manipulation.

It must equally protect lawful private title from being rendered ineffective by erroneous classification, administrative inertia or arbitrary exercise of discretion.

These are not competing principles. They are complementary obligations of lawful governance.

What belongs to the public must remain protected.

What belongs lawfully to a citizen must remain legally secure.

What is lawful need not be obstructed merely because it is administratively inconvenient; what is unlawful must not be protected merely because it has acquired administrative permanence.

The State does not create truth merely by entering something in a register. The register must faithfully reflect the law, the evidence and the legally established right.

The Test of Land Justice

The ultimate question is not simply:

“Whose land is this?”

It is:

“Whose claim is legally valid, what evidence sustains it, and how faithfully has the State recorded and protected that evidence?”

That is the question Section 22-A must answer.

It is the question Bhu Bharati must answer.

It is the question the Revenue and Registration administrations must answer.

And ultimately, it is the question the State itself must answer.

Section 22-A must remain a shield for public property and legally protected interests, never an arbitrary instrument for immobilising lawful private rights.

A land record is not merely a government file.

It is the State’s documentary affirmation of a citizen’s right.

Governments may change. Political dispensations may change. Portals may change. Officers may change. Procedures may change.

But the truth of a lawful land right must not change with them.

For Telangana and Andhra Pradesh, the task is therefore larger than correcting old entries or replacing one digital platform with another. It is to move from the uncertain authority of an administrative entry to the enduring authority of evidence.

Land administration must ultimately become an administration of truth, title, evidence and public trust.

Let the land record speak.

Let the law decide.

Let the evidence prevail.

Only then can the land record become worthy of the citizen’s trust.