Few subjects generate as much rural litigation as the disputed inch of a field boundary. Chapter IV of the Uttar Pradesh Revenue Code, 2006 (Sections 20 to 28) supplies the administrative machinery for fixing, demarcating, maintaining and adjudicating boundaries and boundary marks. It replaced the scattered boundary provisions of the repealed U.P. Land Revenue Act, 1901 and the U.P. Zamindari Abolition and Land Reforms Act, 1950, consolidating them into a single, summary, time-bound scheme. The chapter's guiding idea is simple: every village and every survey number must be physically marked on the ground, those marks must be maintained at someone's cost, and where they are disturbed a revenue officer can restore them quickly without forcing parties into protracted civil litigation. Yet the chapter is equally careful to fence off questions of title from questions of boundary — a distinction that has driven a steady stream of writ petitions before the Allahabad High Court.
The statutory scheme and its source
The Uttar Pradesh Revenue Code, 2006 received the President's assent in 2012 and came fully into force on 11 February 2016 (a few preliminary sections having commenced on 18 December 2015). It repealed some thirty-nine enactments, chief among them the U.P. Land Revenue Act, 1901 and the U.P. Zamindari Abolition and Land Reforms Act, 1950, and re-cast their content into a single instrument. Boundaries and boundary marks occupy Chapter IV, comprising Sections 20 to 28. The chapter follows logically from the survey and settlement operations dealt with elsewhere in the Code: once land has been measured and numbered, its limits must be marked and kept marked. For the surrounding framework see our notes on Revenue Survey and Settlement and the Introduction to the UP Revenue Code, and for the broader subject the hub at UP Revenue Code notes. Chapter IV is deliberately summary in character; it is administrative plumbing rather than a forum for the final determination of proprietary rights.
Section 20 — Fixation and demarcation of boundaries
Section 20 is the foundational provision. It requires that the boundaries of every village and of every survey number (and sub-division of a survey number) be fixed, and demarcated by boundary marks, in the manner and to the standards prescribed by rules made under the Code. The rule-making detail is supplied by the U.P. Revenue Code Rules, 2016, which prescribe the type, dimensions and material of marks — typically masonry pillars, earthen mounds (mends), or pucca trijunction pillars at the meeting of three holdings. The object is that the cadastral map and the field book correspond to identifiable physical features on the ground, so that the abstract survey number is anchored to reality. Fixation under Section 20 is an administrative act flowing from survey and settlement; it does not by itself decide who owns what, only where the recorded line runs. The accuracy of the line is therefore parasitic on the accuracy of the record of rights and the survey map from which it is drawn.
Section 21 — Responsibility for maintenance and repair
A boundary mark is useless if it crumbles and no one rebuilds it. Section 21 allocates the duty of maintenance. The tenure-holder of a holding is bound to maintain, at his own cost, the boundary marks lawfully erected on or for his holding. Boundary marks of other land — village boundaries, marks on land vested in or managed by a Gram Panchayat, and marks not falling on any private holding — are to be maintained at the cost of the Gram Panchayat concerned. The provision thus splits the burden between the private tenure-holder and the local body, mirroring the Code's general allocation of village-level administrative responsibility. The categories of tenure-holder — bhumidhar, bhumiswami and asami — are explained in our note on Definitions: Land, Bhumidhar, Bhumiswami and Asami, and it is the recorded tenure-holder against whom the maintenance obligation runs.
Section 22 — Report of destruction, removal or damage
Section 22 builds the early-warning system. Where a boundary mark is destroyed, removed, injured or rendered ineffective, the Lekhpal (the village accountant who maintains the field records) is to report the fact promptly to the Naib Tahsildar. The Naib Tahsildar then makes such inquiry as he thinks fit and submits a report, with his recommendation, to the Sub-Divisional Officer. The Lekhpal sits at the base of the revenue pyramid and is the officer in daily contact with the village map; his reporting duty makes him the sensor of the system. The chain Lekhpal → Naib Tahsildar → Sub-Divisional Officer reflects the hierarchy of Revenue Officers under the Code, with the SDO as the operative decision-maker for enforcement.
Section 23 — Power to enforce erection, repair or renewal
Section 23 gives the enforcement teeth. The Sub-Divisional Officer may, by order, require a Gram Panchayat or a tenure-holder (as the case may be) to erect, repair or renew any boundary mark which that body or person is bound to maintain. If the order is not complied with within the time allowed, the SDO may cause the work to be carried out by the revenue establishment and recover the cost incurred from the defaulting Gram Panchayat or tenure-holder as if it were an arrear of land revenue. This self-executing cost-recovery mechanism is characteristic of revenue law: the State acts first and recovers later, avoiding the delay of a money suit. The provision dovetails with Section 21, since the person liable to do the work is the person on whom Section 21 places the maintenance burden.
Section 24 — Disputes as to boundaries
Section 24 is the heart of the chapter and the source of most reported litigation. The Sub-Divisional Officer may, on his own motion or on the application of an interested person, decide by summary inquiry any dispute regarding the boundary of any land. The dispute is to be resolved primarily on the basis of the existing survey map (or, where consolidation has taken place, the map prepared under the U.P. Consolidation of Holdings Act, 1953). Where the boundary cannot be determined from the maps, it is to be fixed on the basis of actual possession. Sub-section (2) empowers the SDO, where the possession is found to be wrongful or doubtful, either to determine who is best entitled to possession and put that person in possession, or to restore a wrongfully dispossessed person to possession, using such force as may be necessary. The proceeding is time-bound: it is to be concluded within three months from the date of application (extended to six months by U.P. Act No. 4 of 2016). An appeal lies to the Commissioner within thirty days, subject to Section 210 (as substituted by U.P. Act No. 7 of 2019). The procedure is the modern successor to the old boundary-dispute jurisdiction of the 1901 Act.
Summary jurisdiction, not a title court
The defining limitation on Section 24 is that it confers a summary demarcation jurisdiction, not a power to adjudicate title. The SDO decides where the recorded boundary runs and restores possession in accordance with it; he does not pronounce on ownership, adverse possession or competing claims of title, which remain the exclusive province of the civil court. This separation runs through Indian revenue law generally — revenue authorities have repeatedly been held to lack jurisdiction to decide title disputes — and it is reinforced within the Code itself by the Second Schedule, clause (1) of which bars the civil court from entertaining any question regarding the demarcation of boundaries or the fixing of boundary marks, while leaving questions of title to the civil forum. The two jurisdictions are thus complementary: the revenue officer draws the line on the ground, the civil court decides who owns the land on either side of it.
Boundary proceedings and the civil suit — Pankaj Srivastava
Because Section 24 is summary, its pendency does not freeze the civil court. In Pankaj Srivastava v. Malti Devi, 2023 SCC OnLine All 2155, the Allahabad High Court (Jayant Banerji, J.) held that a suit for permanent injunction can proceed independently of demarcation proceedings under Section 24. The court declined to reject the plaint under Order VII Rule 11 of the Code of Civil Procedure, 1908, reasoning that proceedings under Section 24 are summary in nature while an injunction suit is a regular suit seeking a distinct relief. The mere pendency of, or the availability of, demarcation proceedings does not oust the civil court where the plaintiff seeks injunctive protection of possession rather than the fixing of a boundary. The decision illustrates the Second Schedule's logic in practice: a demarcation question goes to the SDO, but a possessory or proprietary claim is for the civil court, and the existence of one remedy does not bar the other.
Enforcement of demarcation orders — Meena Devi
A demarcation order is worthless if it is never executed on the ground, and chronic non-execution prompted the Allahabad High Court's intervention in Meena Devi v. State of U.P., 2025 SCC OnLine All 8494 (Dr. Yogendra Kumar Srivastava, J.). Hearing a batch of writ petitions where final orders under Section 24 had been obtained but never implemented, the court flagged "systemic inaction" by revenue authorities, observing that the end relief remained illusory despite the statutory procedure being complete. It held that proceedings under Section 24 are not truly "concluded" until the physical affixation of boundary marks and restoration of possession have actually been carried out on the spot, and that the Sub-Divisional Officer and Collector are statutorily bound to enforce such orders. The court issued comprehensive guidelines — covering registration of applications, time-bound demarcation, possession restoration with geo-tagged photographic verification, monitoring and accountability for delay — to be circulated state-wide. The judgment reads Section 24 purposively: the duty to demarcate carries with it the duty to execute.
Sections 25 and 26 — Rights of way and removal of obstructions
Chapter IV also handles the disputes that cluster around boundaries: access and obstruction. Section 25 empowers the Tahsildar to decide disputes regarding the right of way of a tenure-holder, or of an agricultural labourer, to his land or to a source of irrigation, having regard to prevailing custom and the convenience of the parties. Section 26 empowers the Tahsildar to order the removal of any obstruction unlawfully causing impediment to a public road, path, passage or to access to a source of water, and to recover the cost of removal from the person responsible. These provisions give the Tahsildar a quick, possessory jurisdiction over the practical incidents of rural land use — the cart-track, the irrigation channel, the encroachment on the village path — without converting every such quarrel into a regular suit.
Section 27 — Revision by the Sub-Divisional Officer
Section 27 supplies an internal check on the Tahsildar's orders under Sections 25 and 26. The Sub-Divisional Officer may, within thirty days, call for and examine the record of any case decided by the Tahsildar under those sections for the purpose of satisfying himself as to the legality or propriety of the order, and may pass such order as he thinks fit. This is a revisional, not appellate, power — confined to legality and propriety rather than a full re-hearing on merits — and it keeps supervision of the Tahsildar's summary access-and-obstruction jurisdiction within the revenue hierarchy. The thirty-day limit mirrors the appeal period under Section 24(4), giving the chapter a consistent rhythm of swift, time-bound correction.
Section 28 — Saving of civil rights
Section 28 is the chapter's saving clause and the doctrinal counterpart to the summary character of Sections 24 to 27. It provides that nothing in the preceding sections, and no order passed under them, shall debar any person from establishing a right of easement, or any other civil right, by a suit in the civil court. The summary orders bind for the purposes of revenue administration and possession, but they do not extinguish or finally determine substantive civil rights. Section 28 thus completes the architecture explained in our note above on the record of rights: the revenue forum delivers speed and physical demarcation, while the civil forum retains the last word on title and easement. Read together, Sections 20 to 28 give Uttar Pradesh a coherent, two-tier system — quick administrative demarcation on the ground, with the courthouse door left open for the final adjudication of rights.
Frequently asked questions
Which sections of the UP Revenue Code, 2006 deal with boundaries and boundary marks?
Chapter IV, comprising Sections 20 to 28, deals with boundaries and boundary marks. Section 20 covers fixation and demarcation, Section 21 maintenance, Sections 22 and 23 reporting and enforcement, Section 24 boundary disputes, Sections 25 and 26 rights of way and obstructions, Section 27 revision, and Section 28 the saving of civil rights.
Who is responsible for maintaining boundary marks?
Under Section 21, the tenure-holder maintains, at his own cost, the boundary marks on or for his holding. Boundary marks of village boundaries and of land vested in or managed by a Gram Panchayat are maintained at the cost of the Gram Panchayat concerned. Under Section 23 the Sub-Divisional Officer can enforce this duty and recover the cost of any default as an arrear of land revenue.
How is a boundary dispute decided under Section 24?
The Sub-Divisional Officer decides it by summary inquiry, on his own motion or on application, primarily on the basis of the existing survey or consolidation map; where the map cannot resolve it, the boundary is fixed on the basis of actual possession. The SDO may restore a wrongfully dispossessed person to possession. The proceeding must be concluded within three months (six months after the 2016 amendment), with an appeal to the Commissioner within thirty days.
Can a revenue officer decide title in a boundary proceeding?
No. Section 24 confers only a summary demarcation jurisdiction. The SDO fixes where the recorded boundary runs and restores possession, but questions of title, ownership and adverse possession remain with the civil court. The Second Schedule bars the civil court only from questions of demarcation or fixing of boundary marks, leaving title to the civil forum, so the two jurisdictions are complementary.
Does a pending Section 24 demarcation bar a civil suit for injunction?
No. In Pankaj Srivastava v. Malti Devi, 2023 SCC OnLine All 2155, the Allahabad High Court held that a suit for permanent injunction can proceed independently of demarcation proceedings under Section 24, since the former is a regular suit and the latter a summary proceeding. The plaint cannot be rejected under Order VII Rule 11 CPC merely because demarcation is pending or available.
What did the Allahabad High Court say about enforcing demarcation orders?
In Meena Devi v. State of U.P., 2025 SCC OnLine All 8494, the court held that Section 24 proceedings are not "concluded" until boundary marks are physically affixed and possession restored on the ground. It flagged systemic inaction by revenue authorities, held the SDO and Collector bound to enforce such orders, and issued state-wide guidelines requiring time-bound execution, geo-tagged verification and accountability for delay.