Dharani Portal Disputes (TM31): How to Appeal to the Collector and What Remedies Survive

Dharani Portal Disputes (TM31): How to Appeal to the Collector and What Remedies Survive

A practical guide for landowners, house-site holders, buyers and litigants in Hyderabad and Telangana

Introduction

A Dharani portal dispute under TM31 is one of the most common land-record deadlocks in Telangana. TM31 was the module used when the pattadar column showed “House / House Site” and the owner needed either an e-Pattadar Pass Book or a NALA conversion. Those files did not close at the Tahsildar’s desk. They were designed to travel up to the District Collector.

Many of those applications are still pending, rejected without reasons, or stranded after Dharani was replaced by the Bhu Bharati portal. Banks will not lend. A buyer will not close. Registration will not go through. The land is yours on paper, but the revenue system will not treat it as yours.

This article explains what TM31 was meant to do, how CCLA circulars routed the file to the Collector, what changed under the Telangana Bhu Bharati (Record of Rights in Land) Act, 2025, and the remedies that still work in Hyderabad and the districts: portal re-filing, Collector representation, statutory appeal, Prajavani, RTI, and a writ to the Telangana High Court only when the statutory ladder is blocked or delayed without reason.

Read this first

Dharani is no longer the live citizen portal. Current filings run on Bhu Bharati (bhubharati.telangana.gov.in). Legacy TM31 application numbers still matter — keep them. The appeal ladder and limitation under the 2025 Act must be verified against the order you actually hold, because who signed it decides where you file next.

What TM31 actually is

TM31 is not a court case number. It is a Dharani transaction module. Official descriptions — including CCLA Circular No. 1 of 2024 dated 28 February 2024, quoted in Telangana High Court orders such as Vangala Bharat Reddy v. State of Telangana (31 July 2024) — call it:

“Issue of PPB or NALA conversion where name is shown as House/House Site.”

That sentence covers two different requests sitting on the same module.

Issue of Pattadar Pass Book

The digital record shows the land as a house or house site. The owner still needs an e-PPB / title deed so that the holding can be mutated, mortgaged or sold. Without the pass book, the parcel is often invisible for ordinary revenue transactions.

NALA conversion on the same parcel

The owner wants the classification flipped from agricultural use to non-agricultural use, and the Dharani / Bhu Bharati record still carries “House / House Site” in the name field. Telangana High Court has treated TM31 as the Collector-login route for that conversion in specific writs, including a 2022 Medchal-Malkajgiri matter where CCLA itself pointed the Collector to TM31 and asked for conversion tax / penalty to be collected through treasury challan.

A third, quieter problem sits underneath both: the name field itself is wrong. “House / House Site” is a classification tag that leaked into the pattadar column during digitisation. Until that tag is cleaned, neither PPB nor conversion moves.

When a TM31 dispute typically arises

Owners in Hyderabad, Ranga Reddy, Medchal-Malkajgiri, Sangareddy and the rest of Telangana usually hit TM31 in one of these situations:

• Old pass books or pahani show a person as pattadar, but Dharani / Bhu Bharati prints “House / House Site” instead of the name.
• A registered sale deed exists, yet no e-PPB issues because the source record is tagged as house site.
• NALA conversion was paid or applied for, but the portal will not generate the conversion order.
• The application is pending for months in Collector / Additional Collector / RDO login with no speaking order.
• The application is rejected online with a one-line remark and no enquiry report.
• The parcel is also sitting in a prohibited / 22-A / Part-B list, so TM31 cannot even be processed until that flag is lifted.
• After Bhu Bharati went live in 2025, the old Dharani TM31 number no longer opens, and the citizen is told to “apply again” without guidance on which new module replaces TM31.

Do not assume TM31 is the right box for every land problem. Mutation of a clean agricultural sale is TM3. Succession is TM4. Wrongful inclusion in the prohibited list is TM15. Pass-book data correction is TM33. Filing the wrong module is one of the fastest ways to lose six months.

The legal framework you are actually working under

CCLA circulars under the old Dharani system

Two circulars still appear in almost every Hyderabad writ on pending Dharani files:

• CCLA Circular No. 1 of 2021 dated 15 January 2021 — the original operating manual for mutations, grievances and Collector login.
• CCLA Circular No. 1 of 2024 dated 28 February 2024 — further disposal guidelines. For a listed set of modules including TM3, TM4, TM15, TM23, TM24, TM31 and TM33, the Collector was made the final approving authority. The file path was Tahsildar enquiry → RDO → Additional Collector (Revenue) → Collector. Rejection had to carry reasons.

A later CCLA instruction reported in November 2024 delegated final approval on some of those modules — including issue of PPB where the name is listed as house / house site — to the Additional Collector. Treat the current approving officer as a point to verify on the live Bhu Bharati dashboard and the latest CCLA circular before you draft the representation.

Telangana Bhu Bharati (Record of Rights in Land) Act, 2025

Act No. 1 of 2025 repealed the 2020 Dharani-era statute. For new orders, the appeal architecture is in Sections 14 to 16:

• Section 14 — Government may constitute Land Tribunals. Until a Tribunal is notified, the Chief Commissioner of Land Administration is deemed to be the Land Tribunal.
• Section 15 — First and second appeals. As a working map: Tahsildar / Sub-Registrar orders generally go to the RDO; RDO orders generally go to the District Collector (often within 60 days of communication); a further appeal from a Collector order goes to the Land Tribunal (often within 30 days). Exact sub-sections depend on whether the order was a Record of Rights amendment, a mutation, a succession entry or a regularisation under Section 6. Verify the clause against your order.
• Section 16 — Revision.
• Section 18 — Civil-court jurisdiction is restricted for matters the Act channels to revenue authorities. Title disputes are a different animal. Do not treat a mutation appeal as a substitute for a title suit, and do not file a title suit merely to force a portal correction. [To be verified on the exact text of Section 18 against your facts.]

Telangana High Court has already started sending parties back to this ladder. In M. Ranjeesh Reddy v. State of Telangana (7 April 2026) the Court pointed the appellant to the RDO under the 2025 Rules rather than deciding the mutation fight on the writ side. In other matters the Court has treated CCLA as the deemed Land Tribunal under Section 14 where no separate Tribunal has been notified.

Who decides a TM31 file in practice

On a live TM31-type request the usual chain is:

1. Citizen files online (now on Bhu Bharati; earlier on Dharani / MeeSeva) and completes biometric authentication.
2. Tahsildar conducts desk check and field enquiry.
3. RDO scrutinises the enquiry and uploads an order / recommendation.
4. Additional Collector (Revenue) reviews.
5. District Collector (or Additional Collector, if so delegated) approves or rejects with reasons.

For Hyderabad city and the surrounding urban districts the file will sit in one of these Collectorates: Hyderabad, Ranga Reddy, Medchal-Malkajgiri or Sangareddy — depending on the village / municipality of the survey number, not on where you live.

Step-by-step: how to move a stuck or rejected TM31 matter

Step 1 — Reconstruct the paper trail

Before you write to anyone, print and keep:

• The original TM31 / Dharani / Bhu Bharati application number and date.
• SMS acknowledgements and portal status screenshots.
• The rejection remark or the last login stage (Tahsildar / RDO / AC / Collector).
• Old Pattadar Pass Book, title deed, pahani, 1-B, FMB / tippan and registered sale / gift / partition deed.
• NALA challan, conversion application and any earlier conversion proceedings.
• Encumbrance certificate and the current Bhu Bharati land-status print.
• If the land is flagged prohibited, the TM15 / 22-A extract.

Step 2 — File or revive the correct module on Bhu Bharati

Log in at bhubharati.telangana.gov.in. Use the ROR-correction / PPB / NALA / grievance menu that matches the problem. Do not open a fresh TM3 mutation if the only defect is the “House / House Site” tag. Attach readable colour scans. Password-protected PDFs and phone photos of folded pass books are a common silent rejection.

If the portal still exposes a Collector-grievance or “land matters” path, use it and quote the old TM31 number in the narration. The 2021 public position of the department was that Dharani itself allowed a citizen to raise a land-matter grievance that lands in Collector login.

Step 3 — Physical representation to the Tahsildar and RDO

A portal filing that no one opens will not move. File a short physical representation at the mandal office and the RDO office with:

• Application number, survey number, extent, village, mandal, district.
• What the record wrongly shows, and what it should show.
• A numbered list of documents.
• A specific prayer: approve TM31 / successor module, issue e-PPB, or pass a NALA order after collecting tax.

Take an acknowledgement. Ask whether a field inspection is pending. If it is, request a date in writing.

Step 4 — Representation to the District Collector

This is the heart of a TM31 dispute. Address the District Collector of the district where the land sits, with a copy to the Additional Collector (Revenue). Keep the note to three pages.

What the Collector actually needs to see:

• That TM31 / the successor module is the correct channel, citing Circular 1/2024 as applied by the High Court.
• That enquiry has already been done, or that the Tahsildar has sat on it beyond any reasonable period.
• That rejection, if any, is unreasoned — Circular 1/2024 required the Collector to give suitable reasons.
• That you are not asking the Collector to decide a title war between two private parties. If there is a rival claimant, say so honestly and produce the civil-suit number.

File at the Collectorate inward section and, where the district still runs a public hearing day, carry a spare set. Hyderabad-region owners also use Prajavani (prajavani.cgg.gov.in and the physical desks) so that the same grievance is logged with a tracking ID.

Step 5 — Statutory appeal if there is a speaking order

A pending file and a rejected file are different problems. Once there is a reasoned order of the Tahsildar, RDO or Collector, the Bhu Bharati Act appeal clock starts from the date the order is communicated.

1. Identify who signed the order. That single fact decides the forum.
2. Diary the 60-day or 30-day window in Section 15. Do not wait for a “portal appeal button” if the physical appeal is still accepted at the RDO / Collectorate / CCLA inward.
3. Attach the impugned order, the application bundle, and a short ground memo: wrong classification, ignored registered deed, no field enquiry, no notice to the applicant, reasons that do not match the record.
4. Ask for a stay of any further adverse mutation only if someone else is trying to write over your name while the appeal is pending.
5. If the first-appeal order is still wrong, file the second appeal to the Collector or to the Land Tribunal / CCLA as Section 15 requires.

Limitation is unforgiving. If you are even a few days late, plead sufficient cause in the same papers. Do not assume the authority will condone delay on its own.

Step 6 — RTI to force the file to the surface

If the application is pending with no order, file an RTI with the PIO of the Tahsildar / RDO / Collectorate. Ask for: current stage, noting sheet, names of officers who held the file, date of last movement, and copies of any enquiry report or objection. Silence after 30 days is a deemed refusal. First appeal then lies to the departmental FAA. RTI will not rewrite the Record of Rights. It will stop the file from pretending it does not exist.

Step 7 — Writ to the Telangana High Court — only in a narrow band

Article 226 is not the first remedy for a TM31 rejection on merits. The High Court at Hyderabad routinely asks whether you have used the circular / Act ladder. A writ still has a role when:

• The application is pending for an inordinate period and no authority will pass any order.
• The rejection is a portal click with no reasons, no notice and no enquiry.
• The officer who rejected the file had no power under the circular.
• The land has been pushed into the prohibited list on a ground that the record itself contradicts.
• A bank auction, a rival mutation, or a registration freeze will make the statutory appeal useless if you wait.

Typical prayer in Hyderabad practice is a mandamus: consider the named application, follow Circular 1/2021 and 1/2024 / the 2025 Act and Rules, give notice, and pass a reasoned order within a fixed time. The Court often disposes of such writs with exactly that direction and does not declare title. See the pattern in pending-application writs such as the January 2024 order in W.P. No. 2267 of 2024 ( Balapur / Ranga Reddy mutation kept pending) and the remand in Vangala Bharat Reddy.

Documents that actually persuade the Collector

Revenue officers decide TM31 files on documents, not on narrative. Carry this set in a single indexed folder:

• Identity and Aadhaar of the applicant; death certificate and legal-heir proof if you claim through succession.
• Registered title document with schedule matching the survey number.
• Pre-Dharani pass book / title deed and the last manually issued pahani.
• Current Bhu Bharati / Dharani print showing “House / House Site”.
• FMB / tippan / F-Line sketch if extent or sub-division is in issue.
• NALA tax workings, treasury challan and any earlier conversion order.
• EC for at least 13 years, longer if the chain is old.
• Photographs / video of the land — TM31 originally asked for this.
• Court decree or Lok Adalat award, if that is the source of title.
• Proof that the parcel is not assigned / endowment / wakf / government / forest land.

If any document is in Telugu only, file a true translation. If survey numbers were reorganised, add the conversion / correlation statement from the Tahsildar. A mismatch between the deed survey number and the portal survey number is a leading cause of TM31 rejection.

Timelines that matter

There is no single printed “TM31 will be decided in X days” rule that Collectors consistently meet. Use these clocks instead:

• Portal acknowledgement — keep the SMS date. That is Day 0 of delay.
• Field enquiry / F-Line — older Dharani instructions spoke of about 45 days for survey requests. Treat current Bhu Bharati service-level timelines as a point to verify on the live user manual.
• Section 15 first appeal — commonly 60 days from communication of the order, depending on the sub-section.
• Section 15 second appeal — commonly 30 days from communication of the first-appeal order.
• One-year grievance window reported for certain Dharani-era corrections after Bhu Bharati became operational — confirm the start date and whether your district still honours it. A widely circulated diligence note also flags 13 April 2026 as a practical outer date for some RoR corrections. [To be verified before you rely on either date.]
• Writ — no fixed limitation, but delay without explanation weakens a mandamus.
• Civil suit for title — Article 65 / 58 of the Limitation Act, 1963, depending on the cause. Separate advice is required.

Related modules you should not confuse with TM31

• TM3 — ordinary mutation after sale, gift or similar transfer. Collector-final under Circular 1/2024.
• TM4 — succession, including assigned land without PPB.
• TM14 — residual “specific land matters” grievance.
• TM15 — grievance against inclusion in the prohibited-properties list. Often a pre-condition if TM31 will not open.
• TM23 / TM24 — PPB for semi-urban land / court-case PPB.
• TM33 — pass-book data correction (name, pre-Dharani square-yard sale, NALA-to-agriculture flip, missing survey / sub-division, extent).

If the real fight is “this private patta land was dumped into the prohibited list”, start with TM15 / the Bhu Bharati prohibited-list grievance, not TM31. If the real fight is “someone else’s name is on my survey number”, you may need TM3 plus a title strategy, not a house-site PPB.

Common mistakes that sink TM31 files

• Filing TM31 when the land is clearly agricultural patta with a clean name — the module will not cure a different defect.
• Skipping biometric / MeeSeva authentication, so the file never leaves draft.
• Uploading unreadable scans or a deed schedule that does not match the survey number.
• Ignoring a rival claimant. Concealment is discovered at enquiry and the file is rejected.
• Asking the Collector to decide title. Revenue records follow title; they do not create it.
• Jumping to the High Court without a Collector representation or a Section 15 appeal when a speaking order already exists.
• Missing the 30- / 60-day appeal window and then treating a writ as an appeal.
• Paying a tout to “push the login”. Unauthorised alteration of Dharani entries has already triggered district-level enquiries in 2026. Do not become a party to that story.
• Assuming Bhu Bharati auto-cleaned every Dharani error. It did not. The data migrated. The appeal ladder improved. The wrong tag often stayed.

When you should speak to an advocate

Handle a simple pending PPB yourself if the deed, old pass book and portal print tell the same story. Get counsel involved when:

• There is a second claimant, a pending suit, or a criminal complaint on the same survey number.
• The land is assigned, endowment, wakf, ceiling, forest-abutting or already in the 22-A list.
• NALA tax, layout approval (HMDA / DTCP / municipality) and revenue conversion have been mixed up — they are not the same document.
• A bank notice, SARFAESI possession or a court auction is running on the same parcel.
• You need a writ, a Section 15 appeal with stay, or a civil suit for declaration and injunction.

For land inside GHMC / HMDA limits around Hyderabad, also check whether a municipal mutation or property-tax khata is a separate track. Winning TM31 does not automatically rewrite the GHMC register.

Bullet-point checklist

• Confirm the live portal is Bhu Bharati; archive every old Dharani TM31 number.
• Print land status, pahani, EC, deed and old PPB in one folder.
• Match survey number, extent and boundaries across all four.
• Identify whether you need PPB, NALA, prohibited-list removal, or a title suit.
• File or revive the correct module; complete biometric.
• Give a physical set to Tahsildar, RDO and Collector with acknowledgement.
• If rejected, diary the Section 15 limitation from the communication date.
• Use RTI if the file is invisible.
• Use Prajavani as a parallel tracking ID, not as a substitute for the statutory appeal.
• Reserve the Telangana High Court writ for inaction, want of power, or unreasoned rejection.
• Never treat a Collector order as a decree of title.

Conclusion

A TM31 Dharani dispute is usually a classification-and-workflow problem, not a mystery of title. The record tagged the land as house or house site. The pass book or NALA order never issued. The file then stalled in Collector login.

The practical path in Telangana in 2026 is still the same, even after Bhu Bharati replaced Dharani: rebuild the document set, file the correct live module, push the Tahsildar and RDO on paper, and make the District Collector pass a reasoned order. If that order is wrong, use Section 15. If nobody will pass any order, use a focused writ at the Telangana High Court. Skip a rung only when the facts truly justify it.

Disclaimer

This article is for general information for landowners and litigants in Telangana. It is not legal advice and does not create an advocate-client relationship. Land-record modules, CCLA delegations, Bhu Bharati menus and Section 15 limitation periods change. Verify the live portal, the latest circular and the exact order in your file before you act. Outcomes depend on documents, survey identity and whether a rival claim or prohibited-list flag exists.

Related reading

• How to file a DRT stay to stop a bank auction (if the same parcel is under SARFAESI).
• Protecting guarantor property from SARFAESI action.
• Specific performance in India — when courts order performance versus damages (for stalled land sales).
• Filing an execution petition under Order 21 CPC after a money or possession decree.
• Restoring struck-off companies before NCLT Hyderabad (if the pattadar is a struck-off company).

If a TM31 or Bhu Bharati application on your Hyderabad or Telangana land is pending, rejected without reasons, or blocked by a prohibited-list flag, have the record and the registered deed reviewed before you file the next representation or writ. A short, correctly aimed Collector note is cheaper than a year of the wrong module.