- Decision on Valuable Land Worth Over ₹110 Crore Near the World Heritage Site
- Two revision cases filed by the Puri Collector with the approval of the State Government have been allowed.
- Questions raised over the validity of old Hatapatta documents and revenue records ; the 37-year-old order of the Commissioner of Land Records and Settlement has been set aside.
- Settlement Officer directed to restore the land to the Government account immediately.
Kataka, October 2026 : The Konark Sun Temple, a source of pride for Odisha, an unparalleled example of Indian architectural excellence and an invaluable treasure of world heritage, is not merely a historical monument. It is a major pillar of Odisha’s cultural identity, glorious history and tourism-based economic development. Built in the 13th century, this unique Sun Temple was inscribed on the UNESCO World Heritage List in 1984.
Along with the preservation of the temple’s heritage, the planned development of its surrounding areas, expansion of tourism infrastructure, livelihoods of local people and the economic progress of Odisha are of immense importance. In such a historically significant area, every inch of land represents not merely property but an invaluable cultural and collective asset of the State.
Against this backdrop, an important decision by the Board Of Revenue concerning more than 11 acres of land situated in front of the Konark Sun Temple has statewide significance. The present estimated market value of this land is reported to be over ₹110 crore.
In this widely discussed land dispute, Shri Satyabrata Sahu, Member, Board Of Revenue has delivered an important ruling. The order passed in 1989 by the-then Commissioner of Land Records and Settlement has been set aside & the two revision cases filed by the Puri Collector with the approval of the State Government have been allowed.
The decision is being regarded as a significant step towards protecting government property, establishing the original ownership of the land and examining the legal validity of old revenue records.
Considering the high value of the land, its strategic location and its connection with government property, the Puri Collector filed two revision cases before the Board Of Revenue in November 2025. Thereafter, continuous hearings in both cases were conducted from January onwards & various legal and revenue-related issues were examined in detail. Complex matters such as the original title to the land, the validity of old Hatapatta documents, previously prepared revenue records and the legal basis of the claims were taken into consideration.
Recognising the importance of a case involving such a valuable State asset, the Member, Board Of Revenue accorded it priority and examined it accordingly. Protecting government land situated near a world-famous heritage site such as Konark is not merely a responsibility of the revenue administration ; it is also essential for safeguarding the State’s collective assets for future generations.
Background of the Land Dispute
According to the facts of the case, the disputed land situated in Konark Mouza of Puri district was recorded in the old records as Anabadi/Puratana Patita land.
Subsequently, in 1989, a portion of this land was recorded as Sthitiban in the name of a private individual by the court of the Commissioner of Land Records and Settlement. The individual had claimed that the land had been granted to him many years earlier through two Hatapatta documents issued by the erstwhile landlord.
Remarkably, the Commissioner of Land Records and Settlement heard the case and ordered the land to be recorded in the name of the private individual within just two months. The Puri Collector had not been given an opportunity to present the facts adequately.
In support of the claim, evidence relating to long-term possession of the land, cultivation, payment of land revenue and subsequent revenue records had been presented as proof of entitlement. However, the fundamental questions were whether the relevant Hatapatta documents were legally valid, whether the persons claimed to have granted the land possessed the legal authority to transfer it and whether such documents could form a lawful basis for creating Sthitiban rights over the land.
Legal Principles Considered in the Case
The principal legal issue in this case concerns the distinction between possession of land and ownership of land. Even if a person has been in possession of a piece of land for a long period, paid land revenue or had their name entered in revenue records, these facts alone do not automatically establish the legal basis of original ownership.
Where a claim to land rights depends on a lease or settlement made by former intermediaries, the validity of the transaction and compliance with the applicable provisions of the Odisha Estates Abolition Act must be examined. The law may protect rights lawfully created before an estate vested in the State ; however, a right that was never legally established at the outset cannot be validated merely through subsequent entries in revenue records.
Similarly, in the case of a land transaction, the existence of a registered sale deed does not, by itself, constitute conclusive proof of valid title. A transferor generally cannot convey a greater legal right than the one they lawfully possess.
For these reasons, it is essential to examine the original title documents, old Hatapatta records, previous and current revenue records, classification of the land, and the legal procedures through which the claimed rights were created.
Importance of Government Roads and Accurate Land Records
In this dispute, the Tahasildar’s field inspection report concerning the existence of a government road within the larger original plot also assumes considerable importance.
Accurately identifying the relationship between the original and current plots, the actual area and boundaries of the land, and the location of the road is indispensable for protecting government property.
If discrepancies concerning land boundaries, roads and revenue records remain unresolved in a major heritage and tourism destination such as Konark, they could adversely affect public movement, tourism development and the implementation of government plans in the future. Therefore, accurate identification of the land and correction of records, wherever legally required, are of particular importance.
The protection of government land is not limited to safeguarding ownership. It also involves protecting collective assets, safeguarding public interest and establishing a lawful foundation for future development. Particularly in a location that brings Odisha international recognition, the legal status of every inch of land must remain clear.
Final Decision and Directions
Ultimately, the Board Of Revenue has set aside the 1989 order of the-then Commissioner of Land Records and Settlement and allowed the revision cases filed by the State Government.
Directions have been issued to verify the previous and current revenue records, maps, area and boundaries of the land ; carry out necessary corrections to the records in accordance with law; and ensure the protection of the government road and any other government or public property situated at the site.
The Settlement Officer has been directed to restore the land to the Government account immediately.
The decision once again underscores the importance of administrative vigilance in establishing the original legal rights over land, determining the legal validity of old revenue records and protecting government property.
This ruling not only clarifies important legal issues relating to a land dispute but also reinforces the responsibility to preserve Odisha’s invaluable heritage and assets for future generations.
Officials Involved in the Proceedings
Shri Siddhartha Shankar Das appeared on behalf of the State Government during the hearing and legal proceedings. The Additional District Magistrate (Settlement), Puri, the Gopa Tahasildar and the Additional Tahasildar, Gopa, also played important roles in the proceedings.
The role of the concerned officials, the presentation of land-related records and factual information and the examination of the various legal issues were significant in the adjudication of this important revenue dispute.
