FTL, buffer zones and HYDRAA

Every officer posted anywhere near Hyderabad — and increasingly anywhere in Telangana — inherits the lakes problem: tanks whose beds and margins have been layered over with layouts, conventions and compound walls, and a public now watching demolition drives on television. The vocabulary of that fight is FTL and buffer; the new institutional actor is HYDRAA; and the legal terrain is exactly where a Deputy Collector operates, because the revenue record — and its errors — is usually the battleground.

FTL and buffer: the definitions

FTL — Full Tank Level — is the maximum storage level of a tank: the contour up to which water stands when the tank is full. Everything inside FTL is the tank’s water spread — recorded as shikam, government land even in a drought decade — and construction inside FTL is prohibited, full stop.

Around FTL, the building rules add buffer zones in which construction is also barred. The widths come from G.O.Ms.No. 168, MA&UD, dated 07-04-2012:

Water body	Buffer (no construction)
Lakes/tanks of 10 hectares and above	30 m from FTL
Smaller tanks, kuntas and shikam lands	9 m
Canals and nalas wider than 10 m	9 m
Nalas up to 10 m wide	2 m

Any parcel near a water body in the Hyderabad region can be checked against the mapped FTLs on lakes.hmda.gov.in — the first thing to do when a file, a petition or an LRS application touches a lake.

How FTL is fixed — and why it is the weak joint

FTL is not self-evident on the ground; it is fixed by a notification process in which both Irrigation and Revenue act:

1. Irrigation identifies. The Irrigation (Minor Irrigation) department works out the FTL boundary from tank memoirs, village maps and survey data.
2. Revenue verifies. The Revenue department’s survey wing verifies and certifies the boundary against survey numbers — the step that converts an engineering contour into something the land record can hold.
3. Preliminary notification issues through the district-level lake protection committee; objections are taken (30 days);
4. Final notification follows, with demarcation on the ground by pillars.

The systemic weakness: most Hyderabad-area lakes are still only preliminarily notified. Final notifications lag badly, and that gap is the root of much of the litigation — a demolition premised on an FTL that was never finally fixed is fighting with one hand. In 2024–25 the Collectors of the five GHMC-area districts were directed to re-survey and fix FTLs, and the High Court has demanded the state clarify its FTL-fixation procedure. The scale is large: roughly 2,857–2,912 lakes in HMDA limits, about 455 inside the ORR and only 168 within GHMC proper, spread over seven districts.

HYDRAA

The Hyderabad Disaster Response and Asset Protection Agency was created by G.O.Ms.No. 99, MA&UD, dated 19-07-2024, absorbing the old EV&DM wing of GHMC, and is headed by a senior IPS officer as Commissioner. Its mandate: protect government lands, lakes, nalas, parks and public assets from encroachment, plus disaster response.

Jurisdiction is the Telangana Core Urban Region — GHMC plus the ORR belt across Rangareddy, Medchal–Malkajgiri and Sangareddy districts, up to the Outer Ring Road. After the Cabinet decided to give the agency statutory sanctity, an ordinance of 03-10-2024 amended the GHMC Act, 1955, inserting Section 374-B as HYDRAA’s legal backing. Management of lakes and government lands inside the ORR is being transferred to HYDRAA — including, per government announcements, conservation of Osman Sagar and Himayat Sagar from HMWSSB.

The inside/outside split matters to you directly. Inside the ORR, HYDRAA acts. Outside the ORR, lakes remain with the district machinery: Irrigation (Minor Irrigation) as custodian, Revenue for encroachment removal — the Tahsildar and RDO acting under the Land Encroachment Act and the Irrigation Act — and the municipal or panchayat body for building approvals. A district-posted Deputy Collector is, functionally, the HYDRAA of their own tanks.

The drives, and the stated policy. From August–September 2024 (the N-Convention action) through 2025 (Suram/Suroni Cheruvu in February — about 15 acres recovered; Shamshabad drives; the Sandhya Convention demolition at Gachibowli in May 2025), HYDRAA’s demolitions have been high-profile. The stated policy line: residential buildings pre-dating July 2024 with valid approvals are spared; commercial structures in FTL or buffer face action regardless. Independent review (SANDRP’s 2025 assessment) finds lake degradation continuing despite the agency — this is a long war, not a cleared file.

The High Court’s due-process line

The Telangana HC has repeatedly slammed “unilateral” demolitions carried out without notice or hearing — the Alagari Praveen matter is the standing example: a structure with a registered sale deed and 2023 permissions, demolished on 31-01-2025 without fresh notice. The court has warned it would strike down G.O. 99 and shut HYDRAA down if due process continues to be ignored, and has stressed that title disputes belong to civil courts, not to an enforcement agency’s own assessment. NGT proceedings on FTL and buffer encroachments run in parallel.

The takeaway for a revenue officer is exact: enforcement action against a lake encroachment — HYDRAA’s or your own — needs (a) the underlying FTL notification, (b) a notice and an opportunity to be heard, and (c) a record that engages with the occupant’s documents rather than bulldozing past them. The agency’s mistakes are a syllabus of what your own encroachment files must not do.

GO 111 — the twin reservoirs’ catchment

G.O.Ms.No. 111 of 1996 prohibits polluting industry and major construction in the 10-km catchment of Osman Sagar and Himayat Sagar — 84 villages — and is backed by a Supreme Court order of 2000 upholding the protection. The previous government’s 2022 attempt to scrap it (G.O. 69) was widely argued to be contempt of the SC order and was never operationalised; GO 111 remains in force in practice. In mid-2025 the HC issued notices to the state, Irrigation, MA&UD, the Pollution Control Board and five convention-centre owners over large constructions violating it. The present government’s stated position is to protect the catchment (via HYDRAA custody of the reservoirs) while a final land-use policy is worked out; no fresh G.O. replacing GO 111 had issued as of the research date (UNVERIFIED beyond that). For any file touching those 84 villages: assume GO 111 applies until a gazette says otherwise.

A worked example

A Tahsildar in a district just outside the ORR reports that a private layout is being developed touching a 14-hectare tank. The RDO’s file, built properly, runs: pull the tank’s notification status — it turns out to be preliminarily notified only, with objections never disposed; overlay the layout on the FTL line with the mandal surveyor and the Minor Irrigation AE — six plots fall inside FTL on shikam, and a further strip sits within the 30-metre buffer under G.O. 168; check the revenue record — the shikam survey number shows, wrongly, a private khata created in the Dharani years.

The response is therefore three files, not one: (1) a report to the Collector to complete the FTL process — dispose objections, final notification, pillars — because everything else stands on it; (2) encroachment proceedings for the FTL plots under the Land Encroachment Act, with notices, hearing, and a reasoned order dealing with the developer’s documents; (3) a record-correction proceeding on the wrongly created khata through the Bhu Bharati correction channel, since the erroneous entry is what the developer is selling against. The buffer-strip plots go to the local body — the buffer is a building-permission bar under G.O. 168, enforced through planning refusals. Nothing is demolished this week; but nothing about the file will embarrass the state in court either.

Edge cases and common mistakes

• Acting on an un-notified FTL. If the lake is only preliminarily notified, complete the process — or at minimum acknowledge the status and rest the action on the shikam record instead. Pretending the line is final is how cases are lost.
• Confusing FTL with buffer. Inside FTL is government land and encroachment law applies; the buffer is (generally) private land where construction is barred — the tool there is planning permission refusal and demolition of unauthorised construction, not eviction from the land.
• The registered-document trap. A registered sale deed of shikam conveys nothing — but it does entitle the holder to notice, hearing, and an order that explains this. The HC’s ire has been about process, not about protecting encroachment.
• Title adjudication by demolition. Where the occupant’s claim raises a genuine title question, the answer is the civil court or the record-correction channel — flatten the structure and you have converted a winnable case into a compensation claim.
• Forgetting the record is the battleground. Half these disputes trace to a wrong entry — shikam shown as patta, a missing sub-division. Fixing the record through Bhu Bharati channels is slower than a JCB and far more durable.
• The GO 111 blind spot. Layout, NALA and building files from the 84 catchment villages need the GO 111 check regardless of what the applicant’s paper shows.

Questions you’ll actually get

“The plot is in the buffer zone — can the owner even sell it?” Sale is not barred by the buffer; construction is. But disclosure matters, and an LRS or building application on it will be refused or conditioned.

“HYDRAA has asked our office for records of a lake inside the ORR — do we still have a role?” Yes — the revenue record, survey verification and FTL certification remain revenue work even where HYDRAA enforces. Supply certified records and flag known errors; do not certify a line the survey wing has not verified.

“An old house stands inside FTL since the 1990s — do we demolish?” Inside the ORR, the stated policy spares pre-July-2024 residential structures with valid approvals; outside, your Land Encroachment Act discretion must weigh long standing, approvals and hardship — with a reasoned order either way. Old residential occupation is where enforcement most needs process and least forgives bravado.

“Who fixes FTL — Irrigation or us?” Both, in sequence: Irrigation identifies from tank memoirs and survey data; the revenue survey wing verifies and certifies against survey numbers; the committee notifies, hears objections, and finalises. If either department’s step is missing, the line is challengeable.

What to watch in the field

For every tank in your jurisdiction, know three things before any crisis: its notification status (none / preliminary / final), whether its shikam survey numbers stand clean in the record, and whether pillars exist on the ground. A one-page register of your tanks with those three columns — built in your first month — is worth more than any amount of post-demolition drafting skill.