The Rajasthan High Court has ruled that directions for a fresh panchayat reservation lottery cannot operate during the subsistence of the notified election programme. Allowing the State’s appeals, the Court relied on Article 243-O while expressly leaving the substantive legality of the reservation allocation undecided.
Jaipur: A Division Bench of Chief Justice Sanjay K. Agrawal and Justice Sameer Jain has allowed Rajasthan’s appeals against directions requiring a fresh reservation exercise for panchayat elections, holding that the subsequent announcement of the election programme materially changed the position [State of Rajasthan & Others v. Mahendra Singh, with connected appeals].
The reportable judgment, delivered on November 2, 2026, makes a distinction between examining an alleged defect in reservation and granting relief that would reopen electoral arrangements after the election programme has begun.
The dispute and the intervening election programme
In the lead matter, a Single Judge’s October 1 order had quashed the September 24 reservation lottery relating to Gram Panchayat Akbarpur in Karauli district and required a fresh exercise under Rule 7 of the Rajasthan Panchayati Raj (Election) Rules, 1994 and the applicable circulars.
The State defended its method of allocating reserved seats and argued that the rotation requirements had been followed. It also relied on the State Election Commission’s publication of the election programme on October 3, 2026, invoking the constitutional restriction on interference with ongoing panchayat elections.
The respondents disputed the reservation methodology. They argued that their challenge concerned an executive lottery contrary to statutory rules, rather than a challenge to a delimitation law. They also stressed that the Single Judge had ruled before the election programme was announced and that a fresh draw for a panchayat voting in a later phase need not delay the polls.
The effect of relief matters
The Division Bench treated the October 3 programme as a material subsequent development. Under Article 243-O, it explained, electoral disputes must be addressed within the constitutional and statutory framework, including the prescribed election-petition mechanism.
The Court did not hold that every election-related issue lies beyond judicial review. In paragraph 19, it recognised that Article 243-O does not extinguish Article 226 jurisdiction in every circumstance. The decisive question is the nature and effect of the intervention: an order that facilitates the election differs from one that interrupts, obstructs or postpones it.
A fresh reservation lottery could require changes to arrangements already made under the notified programme. The Bench held that confining the direction to one Gram Panchayat did not remove that risk.
Later polling does not create an unrestricted right to reopen reservation
In paragraph 20, the Court rejected the argument that the absence of an individual notification for a particular panchayat was sufficient to permit a fresh exercise. Once the overall programme had been published and remained operative, the election had to be considered as an integrated process with successive stages.
The Bench also held that describing the dispute as a challenge to an administrative lottery could not circumvent the constitutional restriction where the relief would, in substance, alter reservation arrangements governing the election.
Appeals allowed; reservation merits left open
In paragraphs 24 and 25, the Court held that the direction for a fresh reservation exercise could not be sustained during the subsistence of the election programme. It allowed the special appeals and directed that the lottery should not be reopened pursuant to the Single Judge’s order while that programme remained in operation.
The qualification in paragraph 26 is central to the outcome: the Bench did not decide whether the reservation allocation itself was correct. Its findings concerned judicial interference in light of the notified programme, leaving issues that could arise in maintainable proceedings before the competent forum open.
The judgment therefore resolves the appeals without endorsing the State’s reservation methodology on its merits. It explains why a later electoral development can affect whether earlier corrective directions remain capable of being implemented.
Case Title: State of Rajasthan & Others v. Mahendra Singh
Case Numbers: D.B. Special Appeal Writ Nos. 1227/2026, 1228/2026 and 1230/2026
Court: Rajasthan High Court, Jaipur Bench
Bench: Chief Justice Sanjay K. Agrawal and Justice Sameer Jain
Judgment Date: November 2, 2026
Neutral Citation: 2026:RJ-JP:44078-DB
Outcome: Appeals allowed; reservation lottery not to be reopened under the impugned directions during the notified election programme. Substantive reservation merits left undecided.