Supreme Court of India· 06 August 2026

If even one party to a civil dispute over land in a Scheduled Area is a tribal, does the ordinary Civil Court retain jurisdiction under this ruling?

MUKKERA VENKATA RATNAM & ORS v. VANTASALA CHINA VENKATESWARLU & ORS

2026 INSC 810 · C.A. No(s). .... of 2026 (@ SLP(C) Diary No. 21610 of 2022)
Coram: Sanjay Karol; Nongmeikapam Kotiswar Singh

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Answer

No. The Agency Courts retain jurisdiction wherever even one party to the dispute is a tribal residing in the Scheduled Area; the restoration of ordinary Civil Court jurisdiction is confined strictly to civil transactions exclusively between non-tribal parties, so the presence of a single tribal party keeps the matter within the Scheduled Areas jurisdictional bar.

Headnote

Andhra Pradesh Civil Courts Act, 1972 — Scheduled Areas — Civil Court jurisdiction — Constitution of India — Article 14 — Reasonable classification — Binding precedent — Precedent — Binding precedent distinguished from judicial deference to the executive — Held: An order that merely defers to an executive committee's view, without independently discussing the provision's intent and objective, is not binding precedent on that point. (¶9) Andhra Pradesh Civil Courts Act, 1972 — Scheduled Areas notification — Civil Court jurisdiction over non-tribal disputes — Held further: The Scheduled Areas jurisdictional bar protects tribal interests; where every party to a civil dispute is non-tribal, no tribal interest is engaged and the Civil Court retains jurisdiction under Section 9 CPC. (¶13) Constitution of India — Article 14 — Reasonable classification — Intelligible differentia — Held further: Confining the bar to disputes engaging tribal interest, rather than the entire notified area regardless of the parties, rests on an intelligible differentia with a rational nexus to protecting Scheduled Tribes. (¶12, 13) Andhra Pradesh Civil Courts Act, 1972 — Scope of Agency Court jurisdiction — Held further: This applies only to pending and future cases, and restores Civil Court jurisdiction solely where every party is non-tribal; Agency Courts retain jurisdiction wherever even one party is a tribal. Appeal allowed. (¶14, 15, 16)

In the Court's own words

Paragraph 15It is clarified that even if one party to the dispute would be a tribal residing in the Scheduled Areas, then the Agency Courts would retain the jurisdiction. In that view of the matter, ‘Scheduled Areas’, although referring to a specific geographical area, cannot be taken to mean, in view of the object and intent of Schedule V to the Constitution, to be applicable to non-tribal parties. We hold that Nagarjuna supra did not lay down any proposition of law, much less to be a binding precedent. The impugned judgment is set aside, and the second appeal is restored to the file of the High Court to be decided on the merits in a manner consistent with this judgment. Parties to appear before the High Court on 24.08.2026. Hearing expedited.

Acts & Sections

Andhra Pradesh Civil Courts Act, 1972Art.14 Constitution of Indias.9 Code of Civil Procedure, 1908Fifth Schedule Constitution of India

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Also decided in this judgment

What test determines whether a prior court order lays down a binding precedent on a point of law, as opposed to merely deciding the case before it?When only part of a judgment states the reasoning behind a conclusion, which part of that judgment binds later courts as precedent?Under the Andhra Pradesh Civil Courts Act, 1972 and the notification excluding Scheduled Areas, do ordinary Civil Courts have jurisdiction over a partition suit between parties who are all non-tribals, even though the suit property lies within a Scheduled Area?Does confining the Scheduled Areas jurisdictional bar to disputes involving tribal interest, rather than every dispute located within the notified area, satisfy the Article 14 requirement of reasonable classification?

Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections