The prohibited list: Section 22-A and getting off it

Few petitions are as bitter, or as common, as the 22-A petition: a family that has held patta land for generations, paid its dues, and now finds it cannot sell, mortgage or mutate the land because the survey number sits on the “prohibited list” — usually through nobody’s decision at all, just a data operation years ago. Handling these enquiries fairly is core Deputy Collector work under Bhu Bharati, and the officer who understands how the list got poisoned is the one who can clean it without loosing genuinely protected land into the market.

What the list is

Section 22-A of the Registration Act, 1908 (as amended by the state) directs Sub-Registrars to refuse registration of documents relating to notified categories of prohibited property: assigned lands (barred from transfer under the POT Act), endowment and wakf lands, government lands, ceiling-surplus and court-attached lands, and similar protected categories. The list is the interface between the revenue record and the registration system — a survey number on the list is frozen at the Sub-Registrar’s counter, whatever deed a party brings.

The Dharani portal hard-coded this as the “Prohibited Lands” module: the list became a database flag, checked automatically at registration and mutation. Bhu Bharati inherited the module (the portal’s prohibited-lands search continues), and the flag remains decisive: on the list, no registration, no mutation.

How patta land got wrongly swept in

Two operations did the damage:

• The 2017–18 Land Records Updation Programme, a fast statewide purification exercise in which prohibited categories were tagged en masse, with errors of haste baked in.
• The 2020 Dharani migration, which converted those tags into hard portal blocks — with a fatal granularity problem: entire survey numbers were blocked because one sub-division within them was government or assigned land. A survey number of twelve acres with one acre of poramboke in one corner went on the list whole, freezing eleven acres of genuine patta land.

The result, documented across the state: thousands of acres of private patta land on the prohibited list, owners discovering it only at the point of sale, and — because Dharani had no appeal or correction channel — no administrative way out for five years. The problem did not end with the migration: during the Dharani-to-Bhu Bharati re-verification churn of 2025, thousands of owners received fresh 22-A notices, restarting the cycle of alarm and enquiry.

The Bhu Bharati correction route

The Bhu Bharati Act 2025 and its Rules (G.O.Ms.No. 39, Revenue (Lands), dt. 14-04-2025) created what Dharani never had — an administrative road off the list:

1. Application on the Bhu Bharati portal through the correction/grievance channel (the record-correction module, reported as module TM-15 / RoR-corrections), by the owner, with title deeds, the pattadar passbook, and the chain of documents showing the land is genuinely private patta.
2. Field enquiry by the Tahsildar and RDO: tracing the survey number’s history through the khasra pahani and sethwar forward, mapping sub-divisions to establish which portion (if any) is genuinely government/assigned/endowment land, and reporting whether the prohibition tag belongs on this parcel at all — or only on a neighbouring sub-division.
3. The District Collector orders deletion. For most categories the Collector is the competent authority to order removal from the prohibited list, on the enquiry record. Under the correction scheme’s value-linked jurisdiction, higher-value record corrections — the reported threshold is market value above ₹5 lakh — are reserved to the Collector rather than the Tahsildar or RDO (and certain correction types lie with the Collector irrespective of value).
4. The Registration Department unblocks the survey number on the Collector’s orders, and registration and mutation resume.

The window caveat. The Act’s administrative correction scheme for migrated Dharani errors (Section 4(5)) carried a one-year window from commencement — widely reported as closing 13-04-2026. Whether it was extended by later notification is UNVERIFIED; as of August 2026, verify the current instructions before either accepting or rejecting a fresh correction application on limitation grounds. Post-window, the statutory appeal ladder (Section 15), revision (Section 16) and the civil court remain, but the easy administrative road may be shut.

The backstop. Where the owner’s case is genuine and the machinery simply sits on it — the working expectation is disposal in about 90 days — the remedy is a writ of mandamus in the High Court directing consideration. A significant fraction of the HC’s land docket is exactly this: mandamus after mandamus against unexplained 22-A inertia. Every such writ is an institutional failure an officer could have prevented by deciding the file.

A worked example

Sy.No. 214 of a village in a Yadadri-area mandal measures 11.20 acres. Its sub-division 214/2 (1.05 acres) is a recorded government kunta; the rest is patta land held by two brothers under an old registered partition. In the 2017–18 updation the entire Sy.No. 214 was tagged prohibited; Dharani carried the block; a 2024 sale attempt died at the Sub-Registrar’s counter; and in 2025 the elder brother filed a Bhu Bharati correction application with the partition deed, passbooks and pahani extracts back to the khasra pahani.

The Tahsildar’s enquiry, with the mandal surveyor, maps the sub-divisions on the tippan: 214/2 is the kunta, distinctly bounded; 214/1 and 214/3 trace as private patta through every link of the chain, with no assignment, endowment or ceiling history. The RI’s ground check confirms possession matching the record. The RDO forwards the report recommending deletion of 214/1 and 214/3 from the list while expressly retaining 214/2. The parcels’ market value being above ₹5 lakh, the file goes to the District Collector, who orders deletion of the two sub-divisions; the order goes to the District Registrar, the portal flag is lifted sub-division-wise, and the sale registers the following month. The kunta stays protected — which is the whole art: the order that frees the patta land is the same order that nails down what remains prohibited.

Edge cases and common mistakes

• Whole-number thinking. The commonest error in both directions: deleting the entire survey number (releasing the government sub-division with it) or refusing deletion entirely “because part is government land”. The unit of decision is the sub-division; if sub-divisions were never carved, the enquiry must carve them — survey first, order after.
• Assigned land dressed as patta. Some applications are attempts to wash assigned land off the list using later-generation sale documents. The POT Act bar travels with the land; the chain must be traced to origin — an assignment at the root defeats every subsequent deed.
• Endowment and wakf claims. Where the tag rests on an endowment or wakf claim, the enquiry must consult those departments’ records; deleting institution land on the strength of the revenue chain alone is how officers end up in vigilance enquiries. When in doubt, these categories deserve the slowest, best-documented files on your desk.
• The limitation trap — both ways. Rejecting a genuine application solely because the reported window closed, without checking for extensions or the surviving appeal routes, invites a writ; entertaining time-barred applications without verifying the current position invites audit objection. Check the live instruction, and record it in the order.
• Fresh 22-A notices without enquiry. The 2025 re-verification generated bulk notices; treating a notice as a conclusion — and freezing a parcel pending nothing — reproduces the original injustice. A notice opens an enquiry; the enquiry must actually happen.
• Forgetting the refund of confidence. An owner cleared after years off the market has often lost sales, loan seasons and money. Speed is part of the remedy; a correct order two years late is only half correct.

Questions you’ll actually get

“My land has been ours since my grandfather — how did it become ‘prohibited’?” Almost certainly by data operation, not decision: the 2017–18 tagging or the 2020 migration swept it in, often because one sub-division of the survey number is government land. The correction enquiry exists precisely for this.

“The correction window is over — is my land frozen forever?” No. The administrative window (reported as closing 13-04-2026, extension unverified) was the easy road; the Section 15 appeal ladder, Section 16 revision, the civil court, and the writ jurisdiction remain. But move now — every route is slower than the window was.

“Can the Tahsildar remove the entry? Why must it go to the Collector?” The correction jurisdiction is value-linked — the reported line is ₹5 lakh market value, with higher-value cases and certain categories reserved to the Collector — and prohibited-list deletion in most categories is a Collector power. The Tahsildar’s role is the enquiry, not the deletion.

“The Sub-Registrar refused my document but the portal shows my land clear.” Get the refusal in writing with its ground. If the flag was lifted but the registration system has not synced, the fix is administrative (the Collector’s order re-communicated to the District Registrar); if a different tag survives, a fresh enquiry is needed. Never let a refusal remain oral.

“Will buying land on the prohibited list through an agreement of sale protect me?” No. Nothing registers until the parcel comes off the list, and an agreement on genuinely prohibited land (assigned, endowment, wakf) is void protection. Check the prohibited-lands search on the portal before paying — that check is the whole point of the module.

What to watch in the field

When a 22-A enquiry lands on your desk, ask one question before anything else: which sub-division is the reason for the tag? If the file cannot answer it, the enquiry has not begun — send for the tippan and the mandal surveyor, not for more affidavits. Sub-division mapping decides these cases; everything else is paper around it.