State Cannot Name Villages After Individuals in Violation of Its Own Policy: Supreme Court Quashes Rajasthan’s Naming of ‘Amargarh’ and ‘Sagatsar’ as Arbitrary

“Any action taken in derogation of such a policy, without amendment or valid justification, is arbitrary and violative of Article 14 of the Constitution” – Supreme Court on Government’s Obligation to Adhere to Its Own Executive Policy

In a significant decision underscoring the constitutional requirement of non-arbitrariness in executive actions, the Supreme Court on December 19, 2025, quashed a notification issued by the Rajasthan Government naming two newly created revenue villages as ‘Amargarh’ and ‘Sagatsar’, finding that the names were based on private individuals in direct contravention of the State’s binding policy.

Allowing the appeal in Bhika Ram & Anr. v. State of Rajasthan & Ors., a bench comprising Justice Sanjay Kumar and Justice Alok Aradhe held that the notification dated 31.12.2020, naming revenue villages after donors of land, was not only in breach of Clause 4 of the Government Circular dated 20.08.2009 but also amounted to arbitrary State action violative of Article 14 of the Constitution.

The Court restored the order of the Single Judge of the Rajasthan High Court, who had earlier quashed the naming of the villages and directed renaming in accordance with law, while setting aside the subsequent judgment of the Division Bench that had erroneously allowed the State’s appeal.

“State Cannot Be Permitted to Act in Contravention of Its Own Policy” – Supreme Court Reaffirms Doctrine of Self-Binding Executive Policy

At the heart of the case was a simple yet fundamental question of administrative law: Can the State Government act contrary to its declared policy while exercising statutory powers? The Supreme Court’s answer was an emphatic no.

Clause 4 of the Revenue Department Circular dated 20.08.2009, issued by the Government of Rajasthan, categorically mandates:

“While deciding the name, it shall be ensured that it is not based on any person, religion, caste, or sub-caste. As far as possible, the name of the village shall be proposed with general consensus.”

Despite this clear bar, the State Government issued a notification under Section 16 of the Rajasthan Land Revenue Act, 1956 naming two revenue villages as Amargarh and Sagatsar, evidently derived from Amarram and Sagat Singh — individuals who had agreed to donate land for the formation of these villages. The Court found this in direct conflict with the 2009 policy.

Justice Alok Aradhe, delivering the judgment, observed:

“It is well settled in law that a policy decision, though executive in nature, binds the Government, and the Government cannot act contrary thereto, unless the policy is lawfully amended or withdrawn.”

The Court emphasised that such violations strike at the heart of Article 14, which prohibits arbitrary State action.

“Policy Is Not Mere Advice – It Binds the Executive Unless Lawfully Amended” – SC Rebukes State’s Argument That Circular Was Merely Directory

Rejecting the State’s contention that the 2009 circular was only directory and not mandatory, the Court held that the circular embodied a legitimate policy intended to preserve communal harmony and avoid divisive naming of public places. The circular had not been amended or withdrawn, and therefore, the Government was bound by it.

The judgment categorically declared:

“Any action taken in derogation of such a policy, without amendment or valid justification, is arbitrary and violative of Article 14 of the Constitution of India.”

The Court held that there was no exceptional circumstance or public necessity that could justify the deviation. The mere fact that the individuals had donated land could not authorise the State to bypass its own guidelines on naming villages.

“Administrative Legality Requires More Than Procedural Compliance”: SC on Statutory Power under Section 16 of Rajasthan Land Revenue Act

The State had also argued that the procedural requirements under Section 16 of the Rajasthan Land Revenue Act, 1956 had been complied with — including issuance of a notification and determination of village boundaries — and hence, the naming could not be interfered with.

The Court dismissed this defence as a misdirection in law. It clarified that statutory compliance does not immunize executive action from judicial scrutiny when the action is arbitrary, unreasonable, or violates constitutional guarantees.

“No legal sanctity can be attached to the impugned notification dated 31.12.2020, insofar as it pertains to Revenue Villages, namely Amargarh and Sagatsar,” the Court concluded.

“Naming a Village Is Not a Private Honour – It Is a Public Function with Constitutional Consequences” – SC on Arbitrariness and Naming After Individuals

The Court was firm in its view that naming a village after a private person — even one who donates land — sets a dangerous precedent, particularly when such names evoke personal identities, contrary to secular and inclusive governance.

While the State relied on past decisions of the Rajasthan High Court in Moola Ram and Joga Ram, the Supreme Court found that the Division Bench had “failed to consider this material aspect” and wrongly limited itself to analysing whether those earlier decisions applied. The real issue was the violation of policy and Article 14 — not merely the procedural stage of the decision-making process.

Supreme Court Restores Order Quashing the Names and Allows Renaming in Accordance with Law

In allowing the appeal and restoring the Single Judge’s judgment, the Court directed that the villages may be renamed — but strictly in accordance with Clause 4 of the 2009 Circular and the law.

The judgment reinforces the principle that the Government must act within the framework of its own declared policies, especially when such policies are designed to uphold neutrality, prevent favouritism, and ensure equal treatment under law.

The judgment also delivers a warning against populist or politically motivated attempts to name public institutions or places after individuals in contravention of secular and inclusive principles of governance.

Date of Decision: 19 December 2025