Punjab & Haryana High Court: Collector’s Choice of Lambardar Is Not Absolute; Article 226 Judicial Review Permissible Where Selection Ignores Age, Education and Comparative Merit

Case Name: Khaili Ram v. The Financial Commissioner (Revenue), Punjab and Others

Date of Judgment: 05 August 2026

Citation: LPA-354-2023

Bench: Hon’ble Mr. Justice Suvir Sehgal and Hon’ble Mr. Justice Deepinder Singh Nalwa

Held: The Punjab & Haryana High Court held that although the Collector’s choice in the appointment of a Lambardar ordinarily deserves deference and the High Court cannot re-appreciate comparative merits as an appellate authority under Article 226, judicial review is justified where the decision suffers from patent perversity, illegality or ignores relevant criteria. The Court found the selection of the 62-year-old, sixth-pass appellant over Jagat Pal, who was 32 years old, 10+2 qualified and familiar with legal and administrative work, to be perverse. It further held that working as an Advocate’s Clerk is an asset rather than a disqualification for appointment as Lambardar, as it provides familiarity with legal and administrative work.

Summary: The dispute concerned the appointment of a Lambardar for village Kathera, Fazilka. The District Collector appointed Khaili Ram in 2014, and his appointment was subsequently upheld by the Commissioner and Financial Commissioner. Jagat Pal challenged these orders before the High Court, where the Single Judge set them aside and directed his appointment as Lambardar. Khaili Ram consequently preferred the present Letters Patent Appeal.

The Division Bench observed that while the Collector’s choice ordinarily cannot be disturbed merely because another candidate appears preferable, the present selection was patently unreasonable. Jagat Pal was 32 years old and 10+2 qualified, whereas Khaili Ram was 62 years old and sixth-pass. Jagat Pal was also familiar with Lambardari work as his father had served as a Lambardar. The Collector’s finding that the appellant possessed greater experience was unsupported by any material. The Court also rejected the revenue authorities’ view that Jagat Pal’s work as an Advocate’s Clerk was a disadvantage, holding that such experience actually enhanced his familiarity with legal and administrative work. It therefore concluded that the Single Judge had rightly exercised jurisdiction under Article 226 to interfere with a perverse administrative decision.

Decision: The Division Bench dismissed the Letters Patent Appeal and upheld the Single Judge’s judgment dated 14 July 2022, which had set aside the orders of the revenue authorities and directed the appointment of Jagat Pal as Lambardar. The Court held that there was no illegality or infirmity in the Single Judge’s interference under Article 226.