MAPUSA
The Draft Goa Geospatial Knowledge-Based Land Survey of Urban Habitations Rules, 2025 – touted as a modern framework for mapping and recording land in urban and peri-urban areas – has triggered criticism from lawyers, planners and civic groups, who say the proposed regime is riddled with ambiguities that could undermine both procedural clarity and landholders’ rights.
While the draft sets out a broad sequence of notices, surveys, inquiries and publication of records, stakeholders argue that critical definitions are missing.
Terms such as “urban habitations,” “interested persons,” “vacant parcels” and “structures” remain undefined, raising fears that officials may apply inconsistent interpretations when preparing authoritative land records.
A major concern centers on the system of general notice under Form I. The rules require the Director to issue a public notice inviting all persons with an interest in the land to participate, but make no provision for personal service, confirmation of delivery or any mechanism to ensure that landholders are effectively informed.
Since survey work can proceed even if people do not appear, critics warn that affected owners could be excluded from key stages of the process.
Questions have also been raised about the wide discretion granted to survey officers. The draft empowers them to measure parcels and prepare draft records without prescribing measurement standards, verification procedures or methods for resolving boundary disputes. Reviewers say such gaps could result in inaccuracies and disputes at later stages.
The inquiry process, handled by the Inquiry Officer, has drawn sharp comment as well.
“Although the officer is vested with substantial quasi-judicial powers, the draft does not provide any procedural framework for hearings, evaluation of evidence or timelines for decisions. The requirement to ‘hear claimants’ is too vague and risks arbitrary or opaque decision-making,” said Adv Vinayak Porob.
The stages of publication and objections are similarly unclear. The draft does not specify how long draft records must remain open for inspection, the time allowed for objections, the format of objections or how decisions on them will be communicated.
Another contentious point is the directive requiring Inquiry Officers to list vacant or unclaimed parcels. In the absence of verification criteria, stakeholders fear the misclassification of private land as unclaimed, potentially paving the way for administrative use without adequate safeguards.
The draft is also silent on appeal or correction mechanisms once the final landownership record is issued. The re-measurement clause has been faulted for leaving fees entirely to the Inspector’s discretion and for not requiring the presence of interested parties.
“Although Mamlatdars are assigned responsibility for maintaining final records, the rules provide no guidance on incorporating future changes,” said a former town planner, requesting anonymity.
Overall, reviewers say the draft outlines a basic framework but lacks definitions, detailed procedures, clear timelines and essential checks. Unless strengthened, they warn, it may create uncertainty instead of ensuring fairness in urban land administration.
