The Supreme Court quashed orders of the Rajasthan Government that sanctioned the naming of several newly created villages after individual persons, holding that such actions were contrary to the Government’s own established policy on naming and renaming places. The bench noted that once a valid policy is in place, the Government is legally bound to act in accordance with it and cannot take steps that defeat or negate the very purpose and provisions of that policy. The Court’s decision was rendered in a challenge to notifications issued by the State that approved village names which, according to the petitioners, violated the State’s own guidelines prohibiting naming places after living persons or specific individuals without appropriate public consultation and statutory compliance.
The dispute arose when the Rajasthan Government issued a series of orders renaming or naming villages that had been carved out following administrative reorganisation, often selecting names commemorating prominent figures such as political or social leaders. Petitioners contended that the State’s action was ultra vires and unsustainable because the official policy governing place names clearly eschewed the practice of naming habitations or administrative units after individuals without following a transparent consultative process and without regard to objective criteria. They argued that the Government had failed to adhere to its own policy, thereby acting arbitrarily. In response, the State defended its decisions, asserting that the naming of villages after notable individuals could be justified as a matter of honouring contributions to society and community heritage, and that the Government’s discretionary authority extended to such decisions.
The Supreme Court, in considering the challenge, emphasised the well-settled legal principle that the State cannot act contrary to its own proclaimed policy. The bench observed that where a policy has been articulated and publicised, citizens have a reasonable expectation that the policy will be followed and that actions inconsistent with it cannot be upheld under the rule of law. The Court noted that arbitrary deviation from the policy undermines certainty, transparency, and consistency in public administration. It further remarked that adherence to declared policy is an element of good governance and that deviation without cogent justification amounts to mala fide exercise of power.
In its analysis, the Supreme Court examined the relevant Government orders and the guidelines that governed the naming of places within the State. The policy in question contained provisions aimed at ensuring that the nomenclature of localities reflected cultural, historical, or geographical significance, and generally discouraged or prohibited the practice of naming new settlements purely after individuals, especially where such naming was not accompanied by broad public participation or legislative sanction. The Court concluded that the impugned orders, by designating village names based on individuals’ names, were inconsistent with the stated policy and that the State had not demonstrated any compelling rationale to justify departing from its own norms.
The Supreme Court quashed the Government’s notifications insofar as they authorised the naming of villages after persons in contravention of the policy. The Court underscored that the Government must follow its own guidelines and that citizens are entitled to expect compliance with policies that govern administrative actions affecting public rights and interests. The bench clarified that its order did not preclude the naming of places after individuals in appropriate circumstances, but stressed that such measures must be taken within the framework of the policy and must observe the procedural mandates and consultative requirements laid down therein.
By invalidating the State’s actions, the Supreme Court reaffirmed the legal doctrine that the Government must act in conformity with its own policies and cannot adopt inconsistent practices that erode public confidence in administrative processes. The judgment serves as a reminder that regulatory frameworks and procedural norms established by the State carry legal force and that deviation from such frameworks without justification is contrary to principles of fairness, predictability, and lawful governance. The decision emphasises that adherence to declared policies is integral to maintaining the rule of law and ensuring accountability in public administration.
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