Common Judgment:

1. Since the above writ appeals arise out of the same writ proceedings, viz., W.P.No.25826 of 2023 and involve common parties and interconnected issues, the writ appeals are being disposed of by this common judgment.

2. W.A.No.266 of 2026 is directed against the order dated 09.01.2026 passed in I.A.No.2 of 2025 in W.P.No.25826 of 2023, whereby the learned Single Judge dismissed the review application preferred by the appellant–State seeking review of the order dated 27.09.2024 passed in W.P.No.25826 of 2023.

3. W.A.No.274 of 2026 is directed against the order dated 27.09.2024 passed by the learned Single Judge in W.P.No.25826 of 2023, whereby the writ petition was allowed and the appellant–State authorities were directed to release the Rythu Bandhu assistance for the Kharif and Rabi seasons of 2019 in favour of the writ petitioners (respondents herein).

4. Heard Mrs. B. Mohana Reddy, learned Government Pleader for Agriculture and Cooperation Department appearing for the appellants and Mr. M.V.Hanumantha Rao, learned counsel appearing for respondents and perused the record.

Factual matrix

5. The respondents/writ petitioners are agriculturists owning agricultural lands situated in Thelagaram and Thallada Revenue Villages, Thallada Mandal, Khammam District. Respondents have been availing the benefits under the Rythu Bandhu Investment Support Scheme, introduced by the Government of Telangana vide G.O.Ms.No.231, Agriculture and Cooperation Department, dated

04.04.2018. Under the said scheme, investment support was initially extended at the rate of Rs.4,000/- per acre per season, which was subsequently enhanced to Rs.5,000/- per acre per season vide G.O.Rt.No.202, dated 01.06.2019.

6. The grievance of the respondents/writ petitioners is that although they were extended the benefit under the Rythu Bandhu Scheme for all the seasons both prior and subsequent to the year 2019, the investment support for the Kharif and Rabi seasons of 2019 was not released. Aggrieved thereby, they submitted representations before the authorities. As no action was taken thereon, they approached this Court by filing W.P.No.12314 of 2022, which was disposed of on 09.03.2022 with a direction to the 4th respondent–District Agricultural Officer, Khammam, to consider their representations and pass appropriate orders in accordance with law.

7. Pursuant to the aforesaid direction, the 4th respondent addressed a communication dated 16.05.2022, informing the respondents/writ petitioners that their representations seeking release of the Rythu Bandhu assistance for the Kharif and Rabi seasons of 2019 had been forwarded to the Commissioner and Director of Agriculture, Telangana, Hyderabad, since the District Agricultural Officer was not the competent authority to effect payment under the Scheme.

8. Subsequently, the 4th respondent issued proceedings dated 06.12.2022, rejecting the claim of the respondents/writ petitioners. It was stated therein that during the agricultural year 2019-2020, owing to budgetary and resource constraints arising during the COVID-19 pandemic, priority had been accorded to farmers holding lesser extents of land while disbursing financial assistance under the Scheme, subject to the availability of budgetary allocation. It was further stated that the respondents/writ petitioners had otherwise been extended the benefits under the Scheme and that the 2nd respondent/writ petitioner had received a cumulative amount of Rs.3,19,050/- under the Scheme till then. The communication further indicated that the claim relating to the Kharif and Rabi seasons of 2019-2020 stood treated as “lay off”.

9. Aggrieved by the said proceedings dated 06.12.2022, the respondents/writ petitioners instituted W.P.No.25826 of 2023 seeking issuance of a writ of mandamus declaring the action of the respondents in withholding the Rythu Bandhu investment support for the Kharif and Rabi seasons of 2019 as illegal, arbitrary and violative of Articles 14 and 21 of the Constitution of India, and consequently for a direction to release the said amounts.

10. Upon hearing both the parties, the learned Single Judge by order dated 27.09.2024, allowed W.P.No.25826 of 2023 and has made the following observations:

               5. Having heard the submissions and perusal of the record, this Court is of the considered view that as per the counter averments, the petitioners have received Rythu Bandhu amounts for all the years for all seasons from 2018 till 2023 except for the year 2019 due to Covid-l9 pandemic. Pursuant to the direction of this Court in W.P.No.12314 of 2022 dated 09.03.2022, the respondent No.4 gave reply dated 16.05.2022 stating that the payment of amount pertaining to Kariff and Rabi seasons of 2019 was forwarded to the Commissioner and Director of Agriculture. Now, the respondents cannot take different stand for payment of amount for the year, 2019 as the petitioners have received the amounts for subsequent years and the benefit is not extended to the farmers having large extent of lands.

               6. In view of the same, the Writ petition is disposed of directing the respondents to pay the amount under Rythu Bandhu Scheme for Kariff and Rabi seasons of 2019 to the petitioners for their patta lands situated at Thelagaram and Thallada Revenue Viilages, Thallada Mandal, Khammam District, within eight (8) weeks from the date of receipt of a copy of this order. No order as to costs.

11. Aggrieved by the order dated 27.09.2024, the appellants/State preferred I.A.No.2 of 2025 seeking review thereof essentially stting that the judgment of the Hon’ble Supreme Court in Reepak Kansal v. Union of India ((2021) 9 SCC 251) which lays down the principle that Courts cannot interfere with economic policy decisions and cannot issue a mandamus in such matters, was not brought to the notice of the learned Single Judge. The learned Single Judge, after considering the rival submissions dismissed the review application by order dated 09.01.2026, holding that no ground falling within the ambit of Order XLVII Rule 1 CPC had been made out and that there was no error apparent on the face of the record warranting review of the order dated 27.09.2024.

12. Aggrieved by the said orders dated 09.01.2026 passed in I.A.No.2 of 2025 and 27.09.2024 in W.P.No.25826 of 2023, the appellants have preferred the present writ appeals.

Submissions on behalf of the appellants (State)

13. Learned Government Pleader for Agriculture appearing for the appellants, advanced the following submissions:

               i) That the learned Single Judge committed a manifest error in construing the communication dated 16.05.2022 as an acknowledgment of the respondents' entitlement to the Rythu Bandhu assistance for the Kharif and Rabi seasons of 2019.

               ii) That the said communication merely informed the respondents/writ petitioners that their representations had been forwarded to the Commissioner and Director of Agriculture, Telangana, since the District Agricultural Officer was not the competent authority to release the amounts under the Scheme. The said communication neither contained any admission of liability nor constituted an assurance that payment would be made.

               iii) That the subsequent proceedings dated 06.12.2022 specifically assigned the reasons for non-release of the assistance and reflected the policy decision taken by the Government during the relevant period.

               iv) Placing reliance upon the judgment of the Hon'ble Supreme Court in Reepak Kansal (supra 1), the learned Government Pleader submitted that the impugned order is contrary to the principles governing judicial review in matters involving economic policy and allocation of financial resources. It was contended that the Hon'ble Supreme Court in the said judgment has, inter alia, held that:

               a) In matters concerning economic policy and financial relief, Courts ought not to issue a writ of mandamus directing the Government to extend a particular financial benefit;

               b) It is for the Government to determine its priorities and allocate relief among different sectors depending upon prevailing circumstances;

               c) Judicial review in matters involving economic policy is limited, and the Courts ought not to interfere with policy decisions unless they are shown to be arbitrary, irrational or contrary to law;

               d) No State possesses unlimited financial resources and, therefore, the Government is entitled to make pragmatic adjustments while allocating public funds; and

               e) The wisdom or correctness of the reasons which prompted the Government to adopt one policy in preference to another does not ordinarily fall within the scope of judicial review.

               v) That the Government has to decide its own proirities and reliefs to different sectors and that fiscal constraints are a legitimate consideration.

               vi) That the respondents/writ petitioners were neither singled out nor subjected to any hostile discrimination. That the scheme was implemented in a phased manner due to budgetary and financial constraints during the COVID-19 pandemic, the Government adopted a uniform policy across the State by extending the benefit under the Rythu Bandhu Scheme in a phased manner based on the extent of landholding.

               vii) That during the Kharif season of 2019, assistance was extended to farmers holding lands up to 10 acres, whereas during the Rabi season of 2019, the benefit was restricted to farmers holding lands up to 6 acres, subject to availability of funds. Since the respondents/writ petitioners owned lands substantially exceeding the said limits, they were not entitled to receive the benefit for those seasons.

               viii) That the respondents/writ petitioners were not denied the benefit altogether, as they had received assistance under the Scheme for all other seasons, and even during the relevant period, those petitioners having smaller extents of land had received the benefit for the Kharif season of 2019. The policy was uniformly implemented throughout the State and did not target the respondents/writ petitioners individually.

               ix) That the learned Single Judge failed to appreciate the serious financial ramifications of the impugned direction. It was argued that if the benefit is directed to be extended to the respondents/writ petitioners notwithstanding the policy decision, similarly situated landholders across the State would also become entitled to claim the same benefit, thereby opening the floodgates of litigation and imposing an additional financial burden upon the State exchequer to the tune of approximately Rs.2,983.77 crores.

               x) That the review application was preferred on a limited but substantial ground, namely, that the binding judgment of the Hon'ble Supreme Court in Reepak Kansal’s case (supra 1) had not been brought to the notice of the learned Single Judge at the time of hearing of the writ petition despite due diligence. It was contended that non-consideration of a binding precedent of the Hon'ble Supreme Court constitutes a valid ground for review and that the learned Single Judge ought to have reviewed and modified the order dated 27.09.2024 in the light of the law declared by the Hon'ble Supreme Court.

               xi) The learned counsel for the appellants, in support of their case has also placed reliance on the following decisions:

               a) S.Srinivasan and others v. State of Tamil Nadu (2019 SCC OnLine Mad 1345) (para No.12)

               b) S.Bagirathi Ammal v. Palani Roman Catholic Mission ((2009) 10 SCC 464) (para Nos.23 and 24)

Submissions on behalf of the respondents (Writ Petitioners)

14. The learned counsel appearing for the respondents supported the orders passed by the learned Single Judge and have advanced the following submissions:

               i) That the action of the appellants in withholding the Rythu Bandhu assistance for the Kharif and Rabi seasons of 2019 is arbitrary and discriminatory. The respondents/writ petitioners had been extended the benefits under the Scheme for all agricultural seasons prior to and subsequent to the year 2019. Therefore, there was no rational basis for denying the benefit exclusively for the year 2019.

               ii) That the appellants had not framed any specific policy providing for non-payment of the Scheme benefits during the COVID-19 pandemic. On the contrary, the material on record disclosed that several farmers, including those possessing larger extents of land in certain districts, were extended the benefit under the Scheme, thereby demonstrating that the denial of benefits to the respondents/writ petitioners was arbitrary and violative of Article 14 of the Constitution of India.

               iii) That during the hearing of the writ petition, the learned Government Pleader had conceded that there was no specific Government policy withholding payment of the Rythu Bandhu assistance on account of the COVID-19 pandemic. The learned Single Judge has recorded the said submission while allowing the writ petition. It was therefore contended that, in the absence of any such policy decision, the appellants cannot now seek to justify the denial of benefits on the ground of an alleged policy adopted during the pandemic.

               iv) That the decision of the Hon'ble Supreme Court in Reepak Kansal’s case (supra 1) has no application to the facts of the present case. According to the learned counsel, the said decision arose in the context of payment of ex gratia compensation under the Disaster Management Act during the COVID-19 pandemic, whereas the present case concerns the implementation of the Rythu Bandhu Investment Support Scheme, a State-sponsored welfare scheme. It was further submitted that the Hon'ble Supreme Court itself observed that a writ of mandamus can be issued where a statutory or public authority fails to discharge its statutory or public duty and, therefore, the reliance placed by the appellants on the said judgment is misconceived.

               v) That the communication dated 16.05.2022, read in conjunction with the fact that the respondents/writ petitioners were continuously receiving the benefits under the Scheme for all the subsequent years, clearly establishes that the denial of the benefit for the year 2019 was arbitrary. It was contended that the very act of forwarding the respondents/writ petitioners representations to the Commissioner and Director of Agriculture demonstrated that their claim was under active consideration and, therefore, the appellants cannot subsequently contend that the respondents/writ petitioners were not entitled to the benefit.

               vi) That the review application was founded solely on the ground that the judgment in Reepak Kansal’s case (supra 1) had not been cited at the time of hearing of the writ petition. Such a ground, by itself, does not constitute an error apparent on the face of the record warranting exercise of review jurisdiction under Order XLVII Rule 1 of CPC. It was therefore contended that the learned Single Judge rightly dismissed the review application, holding that no case for review had been made out.

15. We have taken note of the respective submissions urged and perused the material placed on record, including the synopsis and the disbursement statements filed by the appellants.

Consideration by this Court

16. In the present case the reliance placed by the learned Single Judge on the communication dated 16.05.2022 for holding that the appellants had admitted their liability to release the Rythu Bandhu assistance for the Kharif and Rabi seasons of 2019 is, in our considered opinion, misplaced. A plain reading of the communication dated 16.05.2022 discloses that it is merely an administrative communication informing the respondents/writ petitioners that their representation had been forwarded to the Commissioner and Director of Agriculture, Telangana, Hyderabad, as the District Agricultural Officer was not the competent authority to effect payment under the Rythu Bandhu Scheme. The communication further states that, upon receipt of appropriate directions from the Commissioner and Director of Agriculture, the same would be intimated to the respondents/writ petitioners.

17. Significantly, the said communication neither acknowledges any legal entitlement of the respondents/writ petitioners to the claimed benefit nor contains any assurance, promise or commitment that the amount would be released. It merely records that the representation had been forwarded to the competent authority for appropriate consideration. The subsequent proceedings dated 06.12.2022, issued by the 4th appellant, specifically assign the reasons for non-release of the benefit by referring to the prevailing budgetary allocation, financial constraints and the policy of according priority to farmers holding smaller extents of land during the relevant period. The said proceedings also record the amounts already received by the respondents/writ petitioners under the Scheme. Therefore, the communication dated 16.05.2022 could not have been construed as an admission of liability or an assurance to release the Rythu Bandhu assistance.

18. It is pertinent to note that the principal contention of the respondents/writ petitioners, that they were extended the benefit under the Rythu Bandhu Scheme for all agricultural seasons preceding and succeeding the year 2019, but were denied the benefit for the Kharif and Rabi seasons of 2019, thereby subjecting them to hostile discrimination, does not merit acceptance. A perusal of the record shows that the implementation of the Scheme during the agricultural year 2019-2020 stood on a different footing owing to the financial constraints faced by the State during the COVID-19 pandemic. The proceedings dated 06.12.2022 specifically attribute the non-release of the benefit to budgetary limitations and the priority accorded to farmers holding smaller extents of land. Therefore, the Government was required to make pragmatic adjustments in the allocation of its limited financial resources.

19. Further, the observation recorded by the learned Single Judge that there was no specific policy governing the non-release of the benefit is not supported by the material subsequently placed before this Court. The proceedings dated 06.12.2022 indicate that the Scheme was implemented in a phased manner by extending priority to farmers holding smaller extents of land. The appellants have further placed material to demonstrate that the respondents/writ petitioners were not singled out for differential treatment and that a large number of similarly situated farmers across the State, whose landholdings exceeded the prescribed limits, were also not extended the benefit during the relevant seasons. It is stated that 1,41,993 farmers could not be extended the benefit for Vanakalam 2019 (Kharif 2019), involving an amount of Rs.850.82 crores, while 9,46,009 farmers were not extended the benefit for Yasangi 2019 (Rabi 2019), involving an amount of Rs.2,132.95 crores. These figures, as placed on record by the appellants, prima facie indicate that the respondents/writ petitioners were not treated differently from other farmers similarly situated.

20. It is also apposite to note that the Rythu Bandhu Investment Support Scheme is a welfare measure introduced by the State Government with the object of providing financial assistance to farmers. The formulation, implementation and manner of disbursement of benefits under the Scheme are essentially matters falling within the realm of executive policy. The material placed on record indicates that, during the agricultural year 2019-2020, the Government, faced with unprecedented financial constraints arising out of the COVID-19 pandemic, adopted a phased implementation of the Scheme by according priority to farmers holding smaller extents of land. Such prioritisation, based on the availability of financial resources and prevailing circumstances, falls within the domain of governmental policy and ordinarily does not warrant judicial interference unless shown to be arbitrary, irrational or violative of any constitutional or statutory mandate.

21. It is well settled that a policy decision does not become vulnerable to challenge under Article 14 of the Constitution merely because it results in hardship to a particular class of persons. So long as the classification is founded on an intelligible differentia having a rational nexus with the object sought to be achieved, and is applied uniformly to all persons falling within the class, it cannot be characterised as arbitrary or discriminatory.

22. Further, the appellants have placed considerable reliance upon the decision of the Hon'ble Supreme Court in Reepak Kansal’s (supra 1), to contend that the direction issued by the learned Single Judge trenches upon matters falling within the domain of governmental economic policy. The relevant paras of the said judgement are extracted hereunder:

               25. An identical question came to be considered by this Court in the recent decision in Small Scale Industrial Manufactures Assn. v. Union of India [Small Scale Industrial Manufactures Assn. v. Union of India, (2021) 8 SCC 511] and this Court had an occasion to consider in detail the scope of judicial review. While considering the other decisions of this Court on the limited scope of judicial review, in paras 60 to 74, this Court has observed and held as under : (SCC pp. 567-71)

               “60. In catena of decisions and time and again this Court has considered the limited scope of judicial review in economic policy matters. From various decisions of this Court, this Court has consistently observed and held as under:

               60.1. The Court will not debate academic matters or concern itself with intricacies of trade and commerce.

               60.2. It is neither within the domain of the courts nor the scope of judicial review to embark upon an enquiry as to whether a particular public policy is wise or whether better public policy can be evolved. Nor are the courts inclined to strike down a policy at the behest of a petitioner merely because it has been urged that a different policy would have been fairer or wiser or more scientific or more logical. Wisdom and advisability of economic policy are ordinarily not amenable to judicial review.

               60.3. Economic and fiscal regulatory measures are a field where Judges should encroach upon very warily as Judges are not experts in these matters.

               61. In R.K. Garg v. Union of India [R.K. Garg v. Union of India, (1981) 4 SCC 675 : 1982 SCC (Tax) 30] , it has been observed and held that laws relating to economic activities should be viewed with greater latitude than laws touching civil rights such as freedom of speech, religion, etc. It is further observed that the legislature should be allowed some play in the joints, because it has to deal with complex problems which do not admit of solution through any doctrinaire or straitjacket formula and this is particularly true in case of legislation dealing with economic matters.

               62. In Arun Kumar Agrawal v. Union of India [Arun Kumar Agrawal v. Union of India, (2013) 7 SCC 1] , this Court (at SCC p. 18, para 43) had an occasion to consider the following observations made the Supreme Court of the United States in Metropolis Theater Co. v. City of Chicago [Metropolis Theater Co. v. City of Chicago, 1913 SCC OnLine US SC 123 : 57 L Ed 730 : 228 US 61 (1913)] :

               43. … ‘2. … The problems of Government are practical ones and may justify, if they do not require, rough accommodation, illogical, if may be, and unscientific. But even such criticism should not be hastily expressed. What is the best is not always discernible; the wisdom of any choice may be disputed or condemned. Mere errors of Government are not subject to our judicial review. It is only its palpably arbitrary exercises which can be declared void.…” (Metropolis Theater Co. case [Metropolis Theater Co. v. City of Chicago, 1913 SCC OnLine US SC 123 : 57 L Ed 730 : 228 US 61 (1913)] , SCC OnLine US SC para 2)’

               63. This Court in State of M.P. v. Nandlal Jaiswal [State of M.P. v. Nandlal Jaiswal, (1986) 4 SCC 566] has observed that the Government, as laid down in Permian Basin Area Rate Cases, In re [Permian Basin Area Rate Cases, In re, 1968 SCC OnLine US SC 87 : 20 L Ed 2d 312 : 390 US 747 (1968)] , is entitled to make pragmatic adjustments which may be called for by particular circumstances. The court cannot strike down a policy decision taken by the State Government merely because it feels that another policy decision would have been fairer or wiser or more scientific or logical. The court can interfere only if the policy decision is patently arbitrary, discriminatory or mala fide.

               64. In BALCO Employees' Union v. Union of India [BALCO Employees' Union v. Union of India, (2002) 2 SCC 333] , this Court has observed that wisdom and advisability of economic policies are ordinarily not amenable to judicial review unless it can be demonstrated that the policy is contrary to any statutory provision or the Constitution. In other words, it is not for the courts to consider relative merits of different economic policies and consider whether a wiser or better one can be evolved. It is further observed that in the case of a policy decision on economic matters, the courts should be very circumspect in conducting an enquiry or investigation and must be more reluctant to impugn the judgment of the experts who may have arrived at a conclusion unless the court is satisfied that there is illegality in the decision itself.

               65. In Peerless General Finance & Investment Co. Ltd. v. RBI [Peerless General Finance & Investment Co. Ltd. v. RBI, (1992) 2 SCC 343] , it is observed and held by this Court that the function of the court is to see that lawful authority is not abused but not to appropriate to itself the task entrusted to that authority. It is further observed that a public body invested with statutory powers must take care not to exceed or abuse its power. It must keep within the limits of the authority committed to it. It must act in good faith and it must act reasonably. Courts are not to interfere with economic policy which is the function of experts. It is not the function of the courts to sit in judgment over matters of economic policy and it must necessarily be left to the expert bodies. In such matters even experts can seriously and doubtlessly differ. Courts cannot be expected to decide them without even the aid of experts. It is further observed that it is not the function of the court to amend and lay down some other directions. The function of the court is not to advise in matters relating to financial and economic policies for which bodies like RBI are fully competent. The court can only strike down some or entire directions issued by RBI in case the court is satisfied that the directions were wholly unreasonable or in violative of any provisions of the Constitution or any statute. It would be hazardous and risky for the courts to tread an unknown path and should leave such task to the expert bodies. This Court has repeatedly said that matters of economic policy ought to be left to the Government.

               66. In Narmada Bachao Andolan v. Union of India [Narmada Bachao Andolan v. Union of India, (2000) 10 SCC 664] , in paras 229 and 233, it is observed and held as under : (SCC pp. 762-63)

               ‘229. It is now well settled that the courts, in the exercise of their jurisdiction, will not transgress into the field of policy decision. Whether to have an infrastructural project or not and what is the type of project to be undertaken and how it has to be executed, are part of policy-making process and the courts are ill-equipped to adjudicate on a policy decision so undertaken. The court, no doubt, has a duty to see that in the undertaking of a decision, no law is violated and people's fundamental rights are not transgressed upon except to the extent permissible under the Constitution.

               ***

               71. The correctness of the reasons which prompted the Government in decision taking one course of action instead of another is not a matter of concern in judicial review and the court is not the appropriate forum for such investigation. The policy decision must be left to the Government as it alone can adopt which policy should be adopted after considering of the points from different angles. In assessing the propriety of the decision of the Government the court cannot interfere even if a second view is possible from that of the Government.

               45. As observed hereinabove, the Government has to decide its own priorities and reliefs to the different sectors/for different reliefs. The Government is required to take various measures in different fields/sectors, like public health, employment, providing food and shelter to the common people/migrants, transportation to migrants, etc. The Government is also required to deal with the effect of the pandemic on the economy. As observed hereinabove, a huge amount is required to be spent from the NDRF/SDRF, even while providing minimum standards of relief. It cannot be disputed that ex gratia assistance would also have financial implications and which may affect the other minimum standards of relief to be provided to the persons affected by disaster. No State or country has unlimited resources. That is why it only announces the financial reliefs/packages to the extent it is possible. When the Government forms its policy, it is based on a number of circumstances, on facts, law including constraint based governmental resources. As observed by this Court in Nandlal Jaiswal [State of M.P. v. Nandlal Jaiswal, (1986) 4 SCC 566] , the Government, as laid down in Permian Basin Area Rate Cases, In re [Permian Basin Area Rate Cases, In re, 1968 SCC OnLine US SC 87 : 20 L Ed 2d 312 : 390 US 747 (1968)] , is entitled to make pragmatic adjustments which may be called for by particular circumstances. As observed by this Court hereinabove, the function of the Court is to see that lawful authority is not abused but not to appropriate to itself the task entrusted to that authority.

               46. Therefore, the courts would be very slow to interfere with priorities fixed by the government in providing reliefs, unless it is patently arbitrary and/or not in the larger public interest at all. The Government should be free to take policy decisions/decide priorities (of course to achieve the ultimate goal of the DMA, 2005, the Government should be free to take its own decisions/priorities while providing minimum standards of relief and even towards preparedness, mitigation, prevention and recovery), subject to the availability of the resources/funds and the amount to be spent towards other reliefs on the aid and advice of the experts and looking to the circumstances from time to time….

               (Emphasis supplied)

23. The learned Single Judge proceeded on the premise that there was no specific policy governing the non-release of the Rythu Bandhu assistance for the Kharif and Rabi seasons of 2019. However, the proceedings dated 06.12.2022, read in conjunction with the pleadings and the material placed before this Court, indicate that the appellants have consistently maintained that, owing to severe financial constraints during the COVID-19 pandemic, the Government adopted a phased implementation of the Scheme by according priority to farmers holding smaller extents of land.

24. It is the specific case of the appellants that, during the Kharif season of 2019, the benefit was extended to farmers holding lands up to 10 acres, whereas during the Rabi season of 2019, the benefit was confined to farmers holding lands up to 6 acres, subject to availability of budgetary allocation. The proceedings dated 06.12.2022 themselves attribute the non-release of the benefit to budgetary allocation, financial constraints and the priority accorded to smaller landholders. Thus, the observation of the learned Single Judge that there existed no policy does not appear to be borne out by the material placed on record.

25. Much emphasis has been laid by the respondents/writ petitioners on the circumstance that certain farmers in the neighboring Suryapet District were extended the benefit notwithstanding the extent of their landholdings. The appellants have explained that the said disbursements constituted an exceptional measure adopted in view of the impending enforcement of the Model Code of Conduct on account of the by-elections in the said district. Merely because an exception was made in a particular district owing to special circumstances, it cannot, by itself, lead to the conclusion that the policy itself was non-existent or that the respondents/writ petitioners were subjected to hostile discrimination.

26. We are also unable to accept the contention that the principles enunciated in Reepak Kansal’s case (supra 1) are inapplicable merely because that case arose out of claims for ex gratia compensation under the Disaster Management Act, 2005. The ratio of the decision is not confined to the facts of that case. Rather, the judgment reiterates the broader principles governing judicial review of governmental decisions in matters involving economic policy, allocation of financial resources and fiscal priorities. Those principles are of general application and are equally relevant while examining the validity of executive decisions concerning the implementation of welfare schemes involving allocation of public funds.

27. The writ Court by issuing a mandamus cannot compel the Government to make a payment that was not budgeted for. The order of the learned Single Judge, if allowed to stand, would not only burden the State exchequer but would also lead to a flood of similar claims from other farmers, who are similarly situated.

28. Insofar as W.A.No.266 of 2026 is concerned, the challenge is directed against the order dismissing the review petition. It is evident from the impugned order that the learned Single Judge dismissed the review petition on the ground that no error apparent on the face of the record was made out. However, the review petition was founded on the specific plea that the decision of the Hon'ble Supreme Court in Reepak Kansal’s case (supra 1), which constituted a binding precedent, had not been brought to the notice of the Court and consequently not considered at the time of disposal of the writ petition.

29. In K.G. Derasari v. Union of India ((2001) 10 SCC 496), the Hon'ble Supreme Court held that where a previous decision of the Apex Court, being the law of the land and binding on the Court, has not been taken into consideration, the remedy available to the aggrieved party is to seek review of the order. The appellants specifically contended that the principles laid down in Reepak Kansal’s case (supra 1) governing the scope of judicial review in matters involving economic policy and allocation of financial resources, had a direct bearing on the controversy in the present case. In our considered view, the learned Single Judge ought to have examined the effect of the said binding precedent while considering the review application. The omission to consider an existing binding precedent, if it has a material bearing on the controversy, constitutes a relevant circumstance warranting consideration in review jurisdiction.

Conclusion

30. For the foregoing reasons, this Court is of the considered view that the communication dated 16.05.2022, being merely an administrative communication, could not have been construed as an admission of liability or an assurance to release the Rythu Bandhu assistance for the Kharif and Rabi seasons of 2019. The phased implementation of the Rythu Bandhu Scheme, adopted in view of the fiscal constraints occasioned by the COVID-19 pandemic, constituted a policy decision to which the principles laid down in Reepak Kansal’s case (supra 1) squarely apply. The learned Single Judge having failed to consider the same, the impugned orders dated 27.09.2024 and 09.01.2026 cannot be sustained and warrant interference by this Court. The orders dated 27.09.2024 passed in W.P.No.25826 of 2023 and order dated 09.01.2026 passed in I.A.No.2 of 2025 in W.P.No.25826 of 2023 are liable to be set aside.

31. Accordingly, Writ Appeals are allowed. The order dated 27.09.2024 in W.P.No.25826 of 2023 and the order dated 09.01.2026 passed in I.A.No.2 of 2025 in W.P.No.25826 of 2023 passed by the learned Single Judge are set aside.

Consequently, miscellaneous petitions pending if any shall stand closed. No costs.