Patna High Court dismisses vague Public Interest Litigation (PIL) from Mushahari, Muzaffarpur

Patna High Court's Division Bench of Chief Justice Sangam Kumar Sahoo and Justice Sudhir Singh delivered a 4-page long judgment on January 12, 2026 in Sunil Shahi vs. The State of Bihar through the Chief Secretary, Government of Bihar & Ors.(2026), wherein it dismissed the Public Interest Litigation (PIL) seeking a comprehensive investigation into the corruption, illegal mutation, forging of records, and disproportionate assets of Circle Officer and revenue officials of Mushahari Anchal. In the 16th judgement authored by Chief Justice Sahoo concluded:"2. Upon perusal of the writ petition, we find that the averments are vague and general in nature. No specific instances have been given in which case and in which district(s) such illegal mutation has been made. 3. So far as the prayer relating to illegal mutation and cancellation of Jamabandi is concerned, the Bihar Land Mutation Act, 2011 provides a statutory mechanism. Under Section 7 of the Act, an appeal against an order of mutation passed by the Circle Officer lies before the Land Reforms Deputy Collector. Further, Section 8 of the Act provides for revision before the Collector or Additional Collector of the District. In cases where a Jamabandi is alleged to have been created in violation of law, Section 9 of the Act empowers the Additional Collector to inquire into and cancel such Jamabandi after giving opportunity of hearing to the concerned parties, with further remedies of appeal and revision provided thereunder. Where an effective and efficacious statutory remedy is available under the law, the same is required to be availed in the first instance, particularly when the allegations pertain to individual mutation entries and land records. 4. In the present case, the writ petition does not disclose that any of the remedies available under the Bihar Land Mutation Act, 2011 have been invoked with respect to any specific mutation or Jamabandi. The reliefs sought are sweeping in nature and seek a general enquiry into all mutation cases over a long period without identification of individual cases. 5. In view of such state of affairs, we are not inclined to entertain the present writ application. 6. Accordingly, the writ petition stands dismissed."

The Public Interest Litigation had prayed for issuance of a writ of Mandamus or any appropriate writ directing the Vigilance Bureau/Anti-Corruption Bureau, Bihar to conduct a comprehensive investigation into the corruption, illegal mutation, forging of records, and disproportionate assets of Circle Officer and revenue officials of Mushahari Anchal. It also sought a Special Investigation Team (SIT) headed by a senior IPS/IAS officer to examine all mutation cases from 2018 to 2025. It prayed for direction to undertake immediate sealing and seizure of the illegal parallel offices run by middlemen in Mushahari Anchal and confiscate all dongles, seals, computers, and revenue documents found therein and cancel all illegal Jamabandi entries, mutations, and land transfers and restore the Government land to its original status, initiate departmental proceedings and suspension of all involved revenue officers and clerks, direct the District Magistrate, Muzaffarpur, to submit periodic reports to the High regarding corrective measures taken, direct the District Magistrate, Muzaffarpur to ensure transparent, corruption-free revenue services, including online processing without agents or bribe-based systems and direct installation of CCTV cameras, complaint redressal system, and mandatory digital processing of all revenue works.