State of Telangana v. Mir Jaffar Ali Khan (D)2025 INSC 1465 - Art. 227 Constitution - Supervisory Jurisdiction - Telangana Forest Act

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Constitution of India - Article 227 - The supervisory jurisdiction confers power on the High Court to set aside orders where the finding of fact is so manifestly perverse or irrational that no reasonable judicial mind could have arrived at it; often described as a perversity apparent to the face of the record. Ancillary and incidental to the above two illustrations, the High Court corrects orders passed in grave dereliction of duty or in flagrant abuse of fundamental principles of law or justice by the court or tribunal subordinate to it. The limitation is that the High Court, in exercise of supervisory jurisdiction, ought not enter into a factual dispute, reweigh the evidence, or substitute its own view for the finding of fact recorded by the subordinate court or tribunal - High Court can and should interfere with findings of fact arrived at by the subordinate court, if they are not based on evidence or based on a manifest misreading of evidence. (Para 20.1)

Telangana Forest Act, 1967 - Section 10 -The inquiry under Section 10 is summary in nature because, upon considering the claim and objection, the FSO does not decide rival claim but merely admits or rejects the claim to a right in or over any land. (Para 25.2)

Case Info


Case Information

  • Coram: Justice Pankaj Mithal; Justice S.V.N. Bhatti.
  • Judgment date: December 18, 2025.

Neutral Citation

  • 2025 INSC 1465.

Caselaws and Citations

  • Mohd. Shaukat Hussain Khan v. State of AP, (1974) 2 SCC 376.
  • Conservator of Forest v. Collector, (2003) 3 SCC 472.
  • Collector v. Bagathi Krishna Rao, (2010) 6 SCC 427.
  • R. Hanumaiah v. State of Karnataka, (2010) 5 SCC 203.
  • Chaman Lal v. State of Punjab, (2014) 15 SCC 715.
  • K.S.B. Ali v. State of A.P., (2018) 11 SCC 277.
  • State of AP (now State of Telangana) v. AP State Waqf Board & Ors., (2022) 20 SCC 383.
  • Trinity Infraventures Ltd. v. M.S. Murthy, (2023) SCC OnLine SC 738.

Statutes/Laws Referred

  • Telangana Forest Act, 1967 (Sections 3, 4, 5, 6, 10, 15, 16).
  • Forest Conservation Act, 1980.
  • Hyderabad (Abolition of Jagirs) Regulation, 1358F (~1949).
  • Commutation Regulation (post-abolition framework).
  • Telangana Atiyat Enquiries Act, 1952 (Atiyat Enquiry Act).
  • Telangana Abolition of Inams Act, 1955 (definitions incl. Arazi-Makta).
  • Land Acquisition Act, 1894.
  • Limitation Act, 1963 (Sections 2(j), 3; Article 65).
  • Constitution of India, Article 227.
  • Code of Civil Procedure, 1908 (Sections 79, 80; Order I; Order XXVII Rule 1; Article 300 context).