Legal Review and Analysis of Divyagnakumari Harisinh Parmar and others vs Union of India and others 2025 INSC 1145
1. Heading of the Judgment
Divyagnakumari Harisinh Parmar and others vs. Union of India and others
Citation: Civil Appeal No. 1479 of 2006, along with connected appeals, decided on September 24, 2025.
Court: Supreme Court of India
Coram: Justice Surya Kant, Justice Dipankar Datta, and Justice Nongmeikapam Kotiswar Singh
2. Related Laws and Regulations
The judgment primarily interprets and applies the following legal frameworks:
The Portuguese Colonial Laws:
Organic Structure of the Lands of Nagar Haveli (Organizacao Agraria), 1919 (OA): This was the key regulation governing land grants (Alvaras) in the territory. Article 12 of the OA, which mandated cultivation conditions and allowed for rescission of grants for non-compliance, was the central provision in dispute.Indian Laws Post-Liberation:
The Dadra and Nagar Haveli Land Reforms Regulation, 1971 (1971 Regulation): This regulation aimed to abolish the oldAlvarasystem and confer occupancy rights on landholders.
Code of Civil Procedure, 1908 (CPC): The judgment discusses the scope of the High Court's jurisdiction in a second appeal under Section 100 of the CPC.
3. Basic Judgment Details
Appellants: Divyagnakumari Harisinh Parmar and other descendants of ori
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