Reasonable-time revisional power and hearing rights bar adverse land revision without notice to directly affected allottees.

Revisional power under Section 34 of the Urban Land (Ceiling and Regulation) Act, 1976, though not subject to a fixed limitation period, must be exercised within a reasonable time, and the revisional authority must consider intervening events such as vesting, allotment, payment and possession before altering earlier proceedings. Where a municipal corporation has been allotted the land, paid the price and taken possession, it is a person directly affected by the revisional process and is entitled to notice and hearing before any adverse order is made. The governing principle is that vested rights cannot be displaced without timely exercise of jurisdiction and fair hearing to all affected parties.

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Issues: (i) Whether revisional power under Section 34 of the Urban Land (Ceiling and Regulation) Act, 1976 could be exercised after a long and unexplained delay and without considering intervening events; (ii) Whether the Municipal Corporation, in whose favour the land had been allotted and possession handed over, was a person affected entitled to notice and hearing before the revisional order was passed.

Issue (i): Whether revisional power under Section 34 of the Urban Land (Ceiling and Regulation) Act, 1976 could be exercised after a long and unexplained delay and without considering intervening events.

Analysis: The revisional power under Section 34 is not subject to a prescribed period of limitation, but where the statute is silent the power must be exercised within a reasonable time. The length of delay, the earlier proceedings, the vesting of land in the State, the allotment to the Corporation, payment of price and subsequent conduct were material circumstances which the revisional authority was bound to consider. The revisional order did not address these factors and was passed after a substantial lapse of time, rendering the exercise of jurisdiction legally infirm.

Conclusion: The revisional order could not validly be sustained after such delay and without considering the relevant intervening circumstances.

Issue (ii): Whether the Municipal Corporation, in whose favour the land had been allotted and possession handed over, was a person affected entitled to notice and hearing before the revisional order was passed.

Analysis: The Corporation had paid the occupancy price, had been put in possession, and was proceeding with development. It was therefore directly affected by any order setting aside the earlier proceedings. The requirement of hearing under the proviso to Section 34 applied to all affected persons, and the Corporation could not be treated as a mere stranger or incidental beneficiary. The revisional authority and the High Court erred in proceeding on the basis that the Corporation had no right to be heard.

Conclusion: The Corporation was entitled to notice and hearing, and the revisional order passed without affording such opportunity was unsustainable.

Final Conclusion: The revisional order and the High Court judgment were set aside, and the matter was remitted to the revisional authority for fresh decision after hearing all concerned parties, including the Corporation.

Ratio Decidendi: Where a statute confers revisional power without prescribing limitation, the power must be exercised within a reasonable time, and any person whose vested rights are directly affected by the proposed exercise of that power must be given a reasonable opportunity of hearing.

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