Bhubaneswar: In a significant ruling concerning government land near the UNESCO-listed Konark Sun Temple, the Odisha Board of Revenue has set aside a 1989 order that recorded more than 11 acres of land in the name of a private individual and directed that the land be restored to the Government account.
The disputed land, located in front of the 13th-century Sun Temple in Puri district, has an estimated market value of more than ₹110 crore, according to the information provided on the case. The ruling was delivered by Satyabrata Sahu, Member of the Board of Revenue, who allowed two revision cases filed by the Puri Collector with the approval of the State Government.
The Board’s decision directs the authorities to verify the old and current revenue records, maps, area and boundaries of the land, make necessary corrections in accordance with the law, and protect the government road and any other government or public property at the site. The Settlement Officer has been directed to restore the land to the Government account immediately.
Dispute over old land records
According to the case details, the disputed land in Konark Mouza was originally recorded as Anabadi/Puratana Patita land. In 1989, the then Commissioner of Land Records and Settlement ordered a portion of it to be recorded as Sthitiban land in the name of a private individual.
The individual had claimed rights over the land on the basis of two Hatapatta documents purportedly issued by the erstwhile landlord. Evidence relating to long-term possession, cultivation, payment of land revenue and subsequent revenue entries was also cited in support of the claim.
However, the central questions before the Board concerned the legal validity of the Hatapatta documents, whether the persons who allegedly granted the land had the authority to do so, and whether the documents could lawfully establish Sthitiban rights over the property.
The revision proceedings also examined the circumstances surrounding the 1989 order. According to the case account, the earlier proceedings were completed within two months, and the Puri Collector had not been given an adequate opportunity to present the State’s position.
Considering the land’s location, value and connection with government property, the Puri Collector filed two revision cases before the Board of Revenue in November 2025. Hearings were subsequently conducted from January onwards, with the Board examining the relevant legal and revenue-related issues.
Possession and ownership examined
A key legal issue in the dispute was the distinction between possession and ownership. Long-term occupation, payment of land revenue or the entry of a person’s name in revenue records does not, by itself, conclusively establish lawful ownership of land.
The proceedings also considered the legal framework governing settlements made by former intermediaries, including the applicable provisions of the Odisha Estates Abolition Act. The validity of the original transaction and the legal basis on which rights were claimed were central to the examination.
The case highlighted the need to scrutinise original title documents, historical Hatapatta records, land classifications and successive revenue entries before recognising ownership rights. A subsequent entry in revenue records cannot, on its own, establish a title that was not legally created in the first place.
Government road and boundaries to be verified
The Tahasildar’s field inspection report concerning a government road within the larger original plot also figured in the proceedings.
The Board has directed verification of the land’s original and present plots, boundaries, area and maps, along with the correction of records wherever legally required. Protection of the government road and other public property at the site has also been emphasised.
Accurate identification of land boundaries and public roads is particularly important in a major heritage and tourism destination such as Konark, where unclear records can complicate public access, infrastructure planning and future development.
Significance for protection of government property
The ruling comes against the backdrop of Konark’s importance as a major cultural and tourism landmark of Odisha. The Sun Temple, built in the 13th century, was inscribed on the UNESCO World Heritage List in 1984.
The land dispute has implications beyond the question of individual ownership, as it concerns the protection of a high-value public asset near a globally recognised heritage site. Clear land titles and accurate revenue records are essential for safeguarding government property and ensuring that future development is undertaken on a lawful basis.
Siddhartha Shankar Das appeared on behalf of the State Government during the proceedings. The Additional District Magistrate (Settlement), Puri, the Gopa Tahasildar and the Additional Tahasildar, Gopa, also played roles in the case.
The Board of Revenue’s decision underscores the importance of examining the legal basis of historical land records and taking corrective action where necessary to protect government land and public assets.
