For nearly five years, the names Amargarh and Sagatsar sat quietly on Rajasthan’s revenue maps as entries in land records from Barmer district. They did not trigger protests and occasionally appeared, as many such villages do, in notifications, affidavits, and official files.In 2025, however, during a larger exercise to redraw gram panchayat boundaries, a question surfaced: who were these two villages named after?That question travelled from a desert village in Barmer to the Supreme Court. It was found that the names of the villages were derived from the individuals who had donated land to the state.The Bench of Justices Sanjay Kumar and Alok Aradhe last week set aside the order of the Division Bench of the Rajasthan High Court that had allowed the villages to retain their names. The SC held that the state government could not depart from its own policy barring villages from being named after individuals, even if the issue was flagged years after the villages were created.The originIn 2020, the Rajasthan government notified the creation of four new revenue villages — Nainoni Darziyon Ki Dhani, Sagatsar, Amargarh and Hemnagar — carved out of revenue village Sohda in Barmer district.According to court records and state notifications, Barmer is located in western Rajasthan, bordering Pakistan, and is one of the state’s largest and most sparsely populated districts.The villages in question fall under Tehsil Gida, in an arid desert region marked by scattered settlements rather than compact habitations, one of the reasons residents sought the creation of smaller revenue villages in the first place. In such areas, habitations often lie several kilometres apart, making land administration from a single revenue village cumbersome.Story continues below this adThe creation of the four villages was an administrative exercise aimed at easing land records and local governance. To meet statutory requirements, two residents, Amarram and Sagat Singh, agreed to donate portions of their land.Before the notification was issued, the Tehsildar certified that all conditions for village creation had been fulfilled. The certificate recorded that the proposed villages were “not associated with any individual, religion, caste or community”, and that there was no dispute regarding their formation.The paperwork moved swiftly. In January 2021, the District Collector (Land Records), Barmer, issued orders specifying the area and population of the new villages. With that, Amargarh and Sagatsar entered official revenue records, their names fixed in documents governing ownership, mutation and inheritance.For several years, the issue lay buried in files and resurfaced only in 2025, when the Rural Development and Panchayati Raj Department initiated a state-wide reorganisation of gram panchayats. As boundaries were revisited and objections invited, residents of Meghwalon Ki Dhani flagged what they said had been overlooked earlier: that Amargarh and Sagatsar appeared to draw directly from the names of the individuals who had donated land.The ruleStory continues below this adUnder Section 16 of the Rajasthan Land Revenue Act, 1956, the state has the power to create and alter revenue villages. However, according to Clause 4 of a 2009 government circular, the proposed name of a village must not be based on “any person, religion, caste or sub-caste”.Courts have repeatedly treated this clause as substantive. Its purpose, the Rajasthan HC has said in earlier cases, is to ensure that “no particular person, caste, sub-caste or religion should be given undue advantage disturbing the communal harmony in the society”.Also in Explained | Why Supreme Court stayed Delhi HC order on Unnao rape convict Kuldeep SengarOrders of HC and SCWhen the dispute over the names of Amargarh and Sagatsar first reached the Rajasthan HC, the court applied the above-mentioned logic, and quashed the 2020 notification, which had created the four villages, in July 2025. The HC allowed the state to rename the villages in accordance with the 2009 government circular.Story continues below this adOn appeal, however, a Division Bench took a narrower view. It focused on timing. The villages had been created in December 2020, while key HC judgments enforcing the naming restrictions were delivered only in 2025. Since the process was neither “pending” nor “in the pipeline”, the Bench held that reopening it would risk unsettling settled administrative decisions, warning that it could “open a Pandora’s Box”.The SC disagreed, arguing that the issue was not retrospectivity. It held that the 2009 circular was already in force when the villages were named. The breach occurred at inception.“The aforesaid circular is in the nature of a policy decision,” the apex court observed, noting that Clause 4 was framed “with an object to maintain communal harmony”. Reiterating settled law, it held that “a policy decision, though executive in nature, binds the Government”, and cannot be ignored unless lawfully amended or withdrawn.Any action taken in violation of such a policy, the court held, “without amendment or valid justification, is arbitrary and violative of Article 14”. Administrative finality, the court made clear, cannot cure an illegality.Earlier caseStory continues below this adThis is not the first time that the naming of newly created revenue villages has come under judicial scrutiny.In February 2025, the Rajasthan HC dealt with a batch of petitions questioning village names such as “Gogaji Ki Jaal”. The court noted that “Gogaji” is a local deity worshipped by a particular community, and held that naming a revenue village after the deity violated Clause 4 of the 2009 circular.The HC held that the naming restrictions were meant to ensure that “no particular person, caste, sub-caste or religion should be given undue advantage disturbing the communal harmony in the society”.