Court’s Decision
The Delhi High Court dismissed a Letters Patent Appeal challenging the allotment of a plot of land for Ramleela celebrations in 2025. The appellant had contested cancellation of its booking and re-allotment of the same plot to another committee. The Court upheld the Single Judge’s decision, affirming that the allottee had both been allotted and successfully organised Ramleela functions in 2023 and 2024, thus fulfilling the requirement of Clause (2) of the Standard Operating Procedure (SOP). Stressing that “mere allegations of non-organisation cannot override documentary evidence confirming that Ramleela was indeed held”, the Court found no merit in the appeal and dismissed it.
Facts
The appellant approached the Court after its booking for a plot at GTB Ground, opposite GTB Hospital, Delhi, for Ramleela celebrations in 2025 was cancelled by the Delhi Development Authority (DDA). The DDA instead allotted the site to another committee, which had been given allotments for the years 2023 and 2024.
The appellant argued that since no Ramleela was organised by the other committee in 2023, they were ineligible under Clause (2) of the SOP, which requires evidence of organising Ramleela functions for at least two years out of the last three. The appellant relied on a police order dated 01.09.2025 noting that “no stage Ramleela was conducted during 2023 at the said ground.”
However, the Single Judge rejected this contention, referring to a letter dated 04.09.2025 from the Deputy Commissioner of Police (DCP) confirming that Ramleela was organised at the same ground on 24.10.2023, coinciding with Dussehra. The Single Judge also relied on previous High Court orders that had restored and confirmed allotments to the successful committee in 2023 and 2024.
Issues
- Whether Clause (2) of the SOP disqualified the successful committee for failing to organise Ramleela in 2023.
- Whether the cancellation of the appellant’s booking and allotment in favour of another committee was arbitrary and contrary to law.
- Whether prior judicial orders confirming allotments for the years 2023 and 2024 were binding on the present dispute.
Petitioner’s Arguments
The appellant argued that mere allotment of land in 2023 did not amount to holding a Ramleela function. They cited the DCP order of 01.09.2025 to claim that no stage performance was organised in 2023. Thus, the successful committee could not satisfy Clause (2) of the SOP, which mandates proof of actual organisation of Ramleela for at least two years out of the preceding three.
The appellant further argued that cancellation of their confirmed booking for 2025 and unilateral re-allotment to another party was contrary to principles of fairness and legality. They sought setting aside of the Single Judge’s order and restoration of their booking.
Respondent’s Arguments
The DDA, represented by standing counsel, argued that the successful committee had been allotted the ground in both 2023 and 2024 and had in fact organised the functions, as confirmed by the DCP’s letter dated 04.09.2025. The respondents submitted that the appellant’s argument selectively relied on one police note while ignoring official confirmation of the Ramleela being held in 2023.
They also pointed out that the issue of allotment had already been considered and decided in earlier writ petitions in 2023 and 2024, where cancellations of the allottee’s bookings were set aside and the bookings confirmed in their favour. Since the appellant had not challenged Clause (2) of the SOP itself, they could not now rely on misinterpretation of that clause to deny allotment to the successful committee.
Analysis of the Law
The Court emphasised that Clause (2) of the SOP requires proof of Ramleela being organised for at least two of the last three years, not necessarily consecutive. The evidence before the Court, including the DCP’s letter and prior judicial confirmations, showed that the successful committee organised the functions in 2023 and 2024.
The Court clarified that conflicting administrative notings cannot override conclusive judicial orders or documentary confirmations. Further, once earlier writ petitions had adjudicated in favour of the successful committee, the matter could not be reopened collaterally in an appeal challenging allotment for 2025.
The Court reiterated that allotments for religious and cultural functions must be governed by fairness, adherence to SOPs, and binding judicial precedents.
Precedent Analysis
- Order dated 18.10.2023 in W.P.(C) 12316/2023 – Cancellation of allotment in 2023 was set aside, allowing the successful committee to proceed with its booking.
- Order dated 23.09.2024 in W.P.(C) 11669/2024 – Challenge to DDA’s allotment in favour of the successful committee in 2024 was dismissed, confirming their booking.
The Court applied these precedents to conclude that the successful committee’s eligibility was already recognised, and their organisation of Ramleela was judicially confirmed.
Court’s Reasoning
The Court held that the appellant’s admission that the successful committee was allotted the land in 2023 and 2024, combined with the DCP’s confirmation of the 2023 Ramleela, satisfied Clause (2) of the SOP.
It reasoned that the appellant’s reliance on the earlier DCP note was misplaced and contradicted by subsequent confirmation. Judicial orders of 2023 and 2024 conclusively settled the fact of the Ramleela being organised.
Therefore, the appellant’s claim that the successful committee had failed to organise two functions in three years was unsustainable.
Conclusion
The High Court dismissed the Letters Patent Appeal, affirming the Single Judge’s order. It upheld the DDA’s decision to cancel the appellant’s booking and allot the site to the successful committee. The Court concluded that the successful committee had duly organised Ramleela in 2023 and 2024, fulfilling SOP requirements, and there was no merit in the appellant’s claims.
Implications
The judgment reinforces that cultural and religious event allotments must strictly comply with SOPs and cannot be challenged based on selective interpretation of administrative records. It also highlights that once judicial orders affirm eligibility in prior years, such findings cannot be re-litigated indirectly.
This decision provides clarity for event organisers, ensuring stability and continuity in allotments for public functions like Ramleela celebrations, while discouraging frivolous challenges.
FAQs
Q1: What does Clause (2) of the SOP for Ramleela allotments require?
It requires proof that the applicant has organised Ramleela functions in at least two of the last three years.
Q2: Can administrative notings like police reports override judicial orders?
No. Judicial orders confirming allotments take precedence and cannot be displaced by conflicting administrative notes.
Q3: Why was the appeal dismissed?
Because evidence and prior judicial orders confirmed that the successful committee organised Ramleela in 2023 and 2024, fulfilling SOP requirements.
