Chapter 3: Land Administration Infrastructure – Institutions and Officers Afzal Hosen Mandal
Chapter 3: Land Administration Infrastructure – Institutions and Officers
By Afzal Hosen Mandal, Legal Advisor & Digital Law Specialist, Afzal & Associates
Published: | Updated: | Reading Time: 48 minutes | Word Count: ~8,800
This chapter is Part I: The Historical and Technical Foundations of Land Records of the Ultimate Professional Treatise on Land Registration and Property Law in Bangladesh.
📑 Table of Contents
- 1. The Bifurcated Mandate: Ministry of Land vs. Ministry of Law
- 2. The Revenue Machinery: Divisional Commissioner to Tahsildar
- 3. The Registration Department: Inspector General to Sub‑Registrar
- 4. Specialised Tribunals: Land Survey Tribunal, Land Appeal Board, Vested Property Tribunal
- 5. Development Authorities as Land Lords: RAJUK, CDA, KDA, RDA
- 6. The Wakf Administrator and Minority Trusts
- 7. The Survey and Settlement Directorate
- 8. Coordination Mechanisms and Institutional Reform
- Chapter References and Further Reading
- How to Cite This Chapter
1. The Bifurcated Mandate: Ministry of Land vs. Ministry of Law
The administration of land in Bangladesh is institutionally schizophrenic. Two central ministries, each with distinct organisational cultures, statutory mandates, and operational priorities, share the domain of land governance. This bifurcation—a legacy of colonial administrative logic that separated "revenue" from "registration"—is the single greatest structural weakness of the land administration system. It generates friction, overlap, and gaps that fraudsters exploit with precision. Understanding the precise division of responsibilities between these two ministries is the first step in navigating the bureaucratic labyrinth.
The Ministry of Land (M/O Land)
The Ministry of Land (Bhūmi Mantraṇālaẏa) is the primary policy‑making and administrative body for all matters relating to land revenue, land records, survey and settlement, government Khas land management, and land reforms. Its mandate is derived from the State Acquisition and Tenancy Act, 1950, the Land Development Tax Ordinance, 1976, and the Land Reforms Ordinance, 1984. The Minister of Land, a member of the Cabinet, is the political head; the Secretary, a senior civil servant of the rank of Senior Secretary, is the administrative head.
The Ministry of Land is responsible for:
| Function | Operational Agency |
|---|---|
| Maintenance and updating of the Record of Rights (Khatian) | AC Land offices in every Upazila |
| Mutation (Namjari) of land upon sale, inheritance, gift, or partition | AC Land and Tahsildar offices |
| Conduct of surveys and settlement operations | Directorate of Land Records and Survey (DLRS) |
| Collection of Land Development Tax (Khajna) | Tahsildar offices through Sonali Bank |
| Management, protection, and settlement of government Khas land | Deputy Commissioner and AC Land |
| Implementation of land reforms (ceiling, distribution of Khas land to landless) | Land Reform Board |
| Administration of vested property (through the Deputy Commissioner as Custodian) | Deputy Commissioner's Vested Property Cell |
| Administration of Wakf properties (in coordination with the Administrator of Wakfs) | Administrator of Wakfs under the Ministry of Religious Affairs, but with land record linkage through Ministry of Land |
| Digital land record management (E‑Porcha, E‑Namjari, National Land Portal) | a2i Programme and Ministry of Land's IT Wing |
| Hearing of mutation appeals and revisions | ADC (Revenue), DC, Divisional Commissioner, Land Appeal Board |
The Ministry of Land operates through a sprawling field administration that reaches down to the Union (the smallest rural administrative unit). The hierarchy is: Ministry (Dhaka) → Divisional Commissioner (8 Divisions) → Deputy Commissioner (64 Districts) → Additional Deputy Commissioner (Revenue) → Assistant Commissioner (Land) at Upazila level → Tahsildar at Union level → Kanungo (Surveyor). This vertical chain of command is critical for understanding the appellate hierarchy for mutation and Khajna disputes.
The Ministry of Law, Justice and Parliamentary Affairs (Directorate of Registration)
The Ministry of Law (Āin, Bicār o Saṅsadīẏa Biṣaẏaka Mantraṇālaẏa) administers the Registration Act, 1908, and the Stamp Act, 1899, through the Directorate of Registration. The Directorate is headed by the Inspector General of Registration (IGR), a senior judicial officer or civil servant, who is the apex administrative authority for all Sub‑Registry offices in Bangladesh.
The Directorate of Registration is responsible for:
| Function | Operational Agency |
|---|---|
| Registration of deeds (Saf Kabala, Baina, Heba, Bonton Nama, Mortgage, Lease, Power of Attorney) | Sub‑Registrar offices (approximately 1,200 nationwide) |
| Maintenance of the Balam Book (the master register of all registered deeds) | Sub‑Registrar offices |
| Issuance of certified copies of registered deeds | Sub‑Registrar offices |
| Conduct of searches and issuance of Non‑Encumbrance Certificates (NEC) | Licensed searching clerks (Talashkari) under Sub‑Registrar supervision |
| Adjudication of stamp duty (in coordination with the Collector of Stamps) | Collector of Stamps (Deputy Commissioner) |
| Refusal of registration and hearing of appeals against refusal | Sub‑Registrar → District Registrar → IGR |
| Licensing and regulation of Dolil Lekhoks (deed writers) | District Registrar |
| Authentication of Powers of Attorney executed abroad | District Registrar (adjudication under Section 33) |
The registration hierarchy is: Ministry of Law (Secretary) → Inspector General of Registration → District Registrar (in each District) → Sub‑Registrar (in each Sub‑District/Upazila). The Sub‑Registrar is the officer before whom the deed is executed and registered. He is the gatekeeper of the land transaction system.
The Institutional Disconnect
The bifurcation of land administration between two ministries creates a fundamental operational problem: the office that registers the deed (Sub‑Registrar, under Law) is not the office that maintains the record of ownership (AC Land, under Land). A Saf Kabala registered at the Sub‑Registrar's office does not automatically update the Khatian. The buyer must separately apply for mutation at the AC Land office—a process that involves a different ministry, a different hierarchy, and a different set of officials. The two systems do not share a unified, real‑time database (though integration is underway through the National Land Portal). Historically, a forged deed could be registered at the Sub‑Registrar's office, entered into the Balam Book, and the AC Land would have no immediate knowledge of it. Conversely, a fraudulent mutation could be carried out at the AC Land office based on a forged Baina that was never actually registered. The fraudster exploits the gap between the two systems.
⚠️ Real‑World Consequence: A classic fraud involves a fraudster obtaining a certified copy of the RS Khatian, forging a Saf Kabala, bribing a Sub‑Registrar clerk to make a back‑dated Balam Book entry, and then applying for mutation at the AC Land office. The AC Land, seeing the Balam Book entry and the mutation application, approves the mutation. The fraudster then sells the property to an innocent buyer. The true owner, whose name was in the Khatian before the fraudulent mutation, discovers the fraud only years later. The litigation that ensues typically involves all three agencies—the Sub‑Registrar, the AC Land, and the civil court—each pointing fingers at the other.
2. The Revenue Machinery: Divisional Commissioner to Tahsildar
The field administration for land revenue is a hierarchical structure inherited from the colonial district administration and adapted by successive reforms. Each tier exercises specific powers, and understanding these powers is essential for pursuing administrative remedies before resorting to litigation.
The Divisional Commissioner
At the apex of the divisional revenue administration is the Divisional Commissioner (Bibhāgīẏa Kamiśanār). Bangladesh is divided into eight administrative Divisions: Dhaka, Chittagong, Rajshahi, Khulna, Sylhet, Barisal, Rangpur, and Mymensingh. The Commissioner is a senior officer of the rank of Additional Secretary to the Government.
In land matters, the Commissioner exercises:
- Revisional Jurisdiction: Under Section 40 of the SAT Act, the Commissioner may call for the record of any case decided by a subordinate revenue officer (DC, ADC Revenue, AC Land) and, if he finds that the order is materially irregular, illegal, or improper, he may revise it. This revisional power is discretionary and is exercised only in cases of manifest error.
- Appellate Jurisdiction: In some matters (e.g., appeals against the DC's order in Certificate Cases for Khajna arrears), the Commissioner is the appellate authority.
- Supervisory Powers: The Commissioner supervises the DCs and the ADC (Revenue) in the Division and conducts periodic inspections of the AC Land offices.
The Commissioner's intervention is typically the last internal administrative remedy before the Land Appeal Board and, ultimately, the High Court Division.
The Deputy Commissioner (DC) and the Additional Deputy Commissioner (Revenue) (ADC Revenue)
The Deputy Commissioner (Jelā Praśāsak) is the chief revenue officer of the District. In the 64 districts of Bangladesh, the DC is an officer of the Bangladesh Civil Service (Administration) cadre, usually of the rank of Deputy Secretary. The DC's land‑related functions include:
| Function | Description |
|---|---|
| Collector of Land Revenue | The DC is the ex‑officio Collector responsible for the collection of Land Development Tax (Khajna) through the AC Land and Tahsildar offices. |
| Custodian of Vested Property | The DC is the ex‑officio Custodian of all vested properties in the district. The Vested Property Cell, headed by an ADC or an AC Land, maintains the Ka and Kha schedules and issues the Vested Property Status Certificates. |
| Collector of Stamps | Under the Stamp Act, 1899, the DC is the Collector of Stamps, responsible for adjudicating the stamp duty payable on instruments, prosecuting stamp fraud, and exercising the pre‑emptive purchase right under Section 47B. |
| Land Acquisition | The DC is the first authority for the acquisition of land under the Land Acquisition and Requisition of Immovable Property Act, 2017. He issues the preliminary notification (Section 4), conducts the inquiry, makes the award, and disburses compensation. |
| Appellate Authority in Mutation | The DC hears appeals against the orders of the ADC (Revenue) in mutation cases. |
The Additional Deputy Commissioner (Revenue) (ADC Rēbhēn'iu) is the functional head of land administration at the district level. He is an officer of the Administration cadre, typically of the rank of Senior Assistant Secretary or Deputy Secretary. The ADC (Revenue) is the workhorse of the district land administration. His specific duties include:
| Duty | Description |
|---|---|
| Mutation Appeals | The ADC (Revenue) hears appeals against the mutation orders passed by the AC Land. This is the most common interaction the legal practitioner has with the ADC (Revenue). An appeal must be filed within 60 days of the AC Land's order, on a prescribed form, with a certified copy of the impugned order and the mutation file. |
| Certificate Cases | The ADC (Revenue) supervises the initiation and execution of Certificate Cases for the recovery of Khajna arrears and other public demands. |
| Khas Land Management | The ADC (Revenue) maintains the district Khas land register, processes applications for the settlement of Khas land, and supervises the eviction of illegal encroachers. |
| Conversion of Agricultural Land | The ADC (Revenue) processes applications for the conversion of agricultural land to non‑agricultural use under Section 91 of the SAT Act. |
The Assistant Commissioner (Land) (AC Land)
The Assistant Commissioner (Land) (Ēsi. Land) is the pivotal field officer in the land administration. Stationed at the Upazila (sub‑district) level, the AC Land is an officer of the Administration cadre, usually a young officer in the early years of his career. There are approximately 495 Upazilas in Bangladesh, each with an AC Land.
The AC Land's functions are the most directly relevant to the conveyancing process:
| Function | Description |
|---|---|
| Mutation (Namjari) | The AC Land receives applications for mutation (Form‑D), forwards them to the Tahsildar for inquiry, holds hearings on objections, and passes the mutation order. This is the AC Land's single most important function for the landowner and the buyer. |
| Land Development Tax (Khajna) Assessment | The AC Land assesses the Khajna payable on each holding, maintains the Khajna ledger, and issues the demand notes. |
| Khas Land Management | The AC Land identifies, protects, and manages government Khas land in the Upazila, conducts eviction drives against illegal encroachers, and processes applications for settlement of Khas land. |
| Certificate Cases | The AC Land initiates Certificate Cases for the recovery of Khajna arrears and may order the attachment and auction of the defaulter's land. |
| Dispute Resolution | The AC Land has a limited mediation role in land boundary disputes and may refer complex title disputes to the civil court. |
The Tahsildar and the Kanungo
The Tahsildar (Tahasiladāra) is the field‑level revenue officer stationed at the Union level (the lowest tier of rural administration). The Tahsildar is the eyes and ears of the AC Land.
His duties include:
| Duty | Description |
|---|---|
| Physical Verification for Mutation | The Tahsildar conducts the spot inspection of the land for which mutation is sought. He measures the plot, verifies possession, interviews the neighbours, and submits his Inquiry Report to the AC Land. The Tahsildar's report is the most important piece of evidence in the mutation file. |
| Khajna Collection | In many areas, the Tahsildar personally collects Khajna from the cultivators, though the government is moving towards online payment through banks and mobile financial services. |
| Field Intelligence | The Tahsildar reports any encroachment on government Khas land, any unauthorised conversion of agricultural land, and any other violation of land laws to the AC Land. |
| Maintenance of Local Registers | The Tahsildar maintains the Union Land Register, which contains the name‑wise index of all landowners in the Union, the Dag‑wise index, and the Khajna ledger. |
The Kanungo (Kānungo) is the head surveyor at the Upazila level. Unlike the Tahsildar, who is a revenue officer, the Kanungo is a technical officer trained in survey and cartography.
His duties include:
- Maintenance of the Mouza Maps: The Kanungo is the custodian of the CS, SA, RS, and BS Mouza Maps for the Upazila. He retrieves specific map sheets for inspection and provides certified copies.
- Demarcation of Boundaries: When a boundary dispute arises during the mutation process, the Kanungo assists the Tahsildar by physically identifying the boundary on the ground with reference to the map, using the traverse points and the tenancy stones.
- Survey Assistance: The Kanungo provides technical support to the AC Land and the higher revenue authorities in matters requiring survey expertise.
3. The Registration Department: Inspector General to Sub‑Registrar
The Directorate of Registration (Nibandhana Adhidaptara), under the Ministry of Law, Justice and Parliamentary Affairs, is responsible for the registration of all deeds and instruments affecting immovable property. Its hierarchy is separate from the revenue administration, and its officers are not interchangeable with the Ministry of Land's officers.
The Inspector General of Registration (Nibandhana Mahāparidarśaka) is the apex administrative officer of the Registration Department. The IGR is typically a senior District and Sessions Judge or an officer of the Administration cadre on deputation.
The IGR's functions include:
- Superintendence: The IGR exercises general superintendence over all District Registrars and Sub‑Registrars. He issues circulars, inspects offices, and enforces discipline.
- Revisional Powers: The IGR hears revisions against the orders of the District Registrar in registration matters. The IGR's decision is the final administrative determination; thereafter, the aggrieved party may seek a writ from the High Court Division.
- Policy and Rule‑Making: The IGR advises the Ministry of Law on amendments to the Registration Rules and on the implementation of new technologies (e.g., e‑Registry, biometric verification).
- Licensing of Dolil Lekhoks: The IGR oversees the system of licensing and regulating deed writers through the District Registrars.
The District Registrar (Jelā Nibandhaka) is stationed at the district headquarters. In many districts, the office of the District Registrar is combined with that of the Sub‑Registrar of the Sadar (headquarters) Upazila.
The District Registrar exercises:
- Original Jurisdiction: In some districts, the District Registrar directly registers deeds for properties within the Sadar Upazila, in addition to the Sub‑Registrar.
- Appellate Jurisdiction: The District Registrar hears appeals against the Sub‑Registrar's refusal to register a deed (Section 72 of the Registration Act, 1908). The appeal must be filed within 30 days of the refusal order. The District Registrar may summon the parties, call for the records, and either confirm the refusal or reverse it and direct registration.
- Adjudication of Foreign Powers of Attorney: Under Section 33 of the Registration Act, a Power of Attorney executed outside Bangladesh must be adjudicated by the District Registrar before it can be used for registration. The adjudication involves verification of the notarisation and the consular authentication.
- Condonation of Delay: Under Section 25, the District Registrar may condone a delay of up to four months in the presentation of a deed beyond the initial four‑month period, upon payment of a fine.
- Licensing of Dolil Lekhoks: The District Registrar conducts the examination for deed writers and issues licences.
The Sub‑Registrar (Sāba‑Rējisṭrāra) is the officer before whom the deed is physically executed and registered. There are approximately 1,200 Sub‑Registry offices across Bangladesh, each corresponding to an Upazila or a part of a City Corporation. The Sub‑Registrar is the gatekeeper of the registration system.
His powers and duties are quasi‑judicial:
- Verification of Identity: The Sub‑Registrar must verify the identity of the executant and the witnesses using their NIDs, photographs, and biometric fingerprints (where the system is operational).
- Private Examination: The Sub‑Registrar must privately examine the executant to confirm that the transfer is voluntary, that the consideration has been received, and that there is no coercion or fraud.
- Scrutiny of the Deed: The Sub‑Registrar must scrutinise the deed to ensure that it is on the correct stamp paper, that the stamp duty, registration fee, LGT, and AIT have been correctly paid, that the property is within his territorial jurisdiction, and that the deed is not prohibited by any law.
- Refusal of Registration: If the Sub‑Registrar finds any defect, he must refuse registration and record a speaking order. The refusal is appealable.
- Entry in the Balam Book: Upon registration, the Sub‑Registrar must ensure that the deed is faithfully copied into the Balam Book, and that the indices (Register I and Register II) are updated.
The Dolil Lekhok (Dalila Lēkhaka) is a licensed professional, not a government employee, who is authorised by the District Registrar to draft deeds for the public. The Dolil Lekhok is typically a person who has passed the District Registrar's examination and holds a renewable licence.
While many Dolil Lekhoks are experienced and competent, they are not lawyers. Complex transactions—those involving inheritance, partition, litigation, or NRB sellers—should be drafted by an Advocate of the Supreme Court specialising in conveyancing, who will then provide the draft to the Dolil Lekhok for fair‑copying onto the stamp paper.
4. Specialised Tribunals: Land Survey Tribunal, Land Appeal Board, Vested Property Tribunal
Beyond the general civil courts, Bangladesh has established specialised tribunals with exclusive jurisdiction over specific categories of land disputes. These tribunals are designed to provide faster, more expert adjudication than the overloaded civil courts, though their effectiveness varies.
The Land Survey Tribunal (Bhūmi Jaripa Ṭribiunāla) was established by the insertion of Section 144A into the SAT Act through an amendment in 1990, in response to the enormous backlog of boundary and Khatian‑related disputes in the civil courts.
Composition:
- A judicial officer of the rank of District Judge or Additional District Judge (the Chairman).
- A technical member, typically a senior officer of the DLRS (such as a Settlement Officer or an Assistant Settlement Officer), who provides survey expertise.
Jurisdiction:
The Land Survey Tribunal has exclusive original jurisdiction over disputes concerning:
- The entries in the finally published Record of Rights (Khatian) and the Mouza Map—specifically, the name of the Malik, the Dag number, the area, the classification of land, and the boundaries.
- Disputes relating to the survey, demarcation, and physical boundaries of the Dag.
- Disputes concerning the assessment of rent (Khajna) in the Khatian.
Procedure:
The procedure before the Tribunal is somewhat summary. The applicant files a petition specifying the entry challenged and the grounds. The Tribunal issues notice to the recorded Malik and any interested parties, holds a hearing, and may direct a local survey by a DLRS surveyor. The Tribunal's order is appealable to the Land Appeal Board, and thereafter subject to the writ jurisdiction of the High Court Division.
Strategic Importance: The Land Survey Tribunal is the correct forum for correcting a factual error in the Khatian—for example, a mis‑recorded boundary, a mistaken Dag number, or an error in the area. For complex title disputes involving forgery, inheritance, or adverse possession, the civil court is the appropriate forum, because the Tribunal's summary procedure is not designed for the full trial of title.
The Land Appeal Board (Bhūmi Āpīla Borḍa) is the apex administrative appellate tribunal for land matters, stationed in Dhaka. It hears appeals and revisions against:
- The orders of the Divisional Commissioner in revenue cases.
- The orders of the Deputy Commissioner and the ADC (Revenue) in mutation appeals and Certificate Cases.
- The orders of the Land Survey Tribunal.
The Board is composed of a Chairman (a senior judicial officer or a retired District Judge) and members drawn from the Administration cadre and the DLRS. The Board's decision on questions of fact is final, subject only to the writ jurisdiction of the High Court Division. A decision of the Land Appeal Board can be challenged by a writ under Article 102 if it is vitiated by an error of law or a violation of natural justice.
Established under the Vested Property Return Act, 2001, the Vested Property Tribunal (Arpita Sampatti Ṭribiunāla) adjudicates claims for the release of properties from the Ka and Kha schedules of vested property. The Tribunal is presided over by a District Judge.
Its jurisdiction is exclusive: no civil court can order the release of a vested property. The claimant must prove that:
- The property was originally owned by the claimant or his predecessor‑in‑interest.
- It was included in the Ka or Kha schedule.
- The claimant is a Bangladeshi citizen and the rightful heir.
- The property is still in the possession of the Custodian.
An appeal against the Tribunal's order lies to the Vested Property Appellate Tribunal (a bench of the High Court Division), and the Appellate Tribunal's decision is final, subject to the writ jurisdiction.
5. Development Authorities as Land Lords: RAJUK, CDA, KDA, RDA
In the major cities of Bangladesh, the development authorities created under the Town Improvement Act, 1953, and other specific statutes are not merely planning and regulatory bodies; they are landlords of vast leasehold estates. Their role in the land transaction process is as important as that of the Sub‑Registrar and the AC Land.
RAJUK is the capital development authority for the Dhaka metropolitan region, established under the Town Improvement Act, 1953. RAJUK is the lessor of thousands of acres of prime residential and commercial land in Gulshan, Banani, Baridhara, Uttara, Nikunja, Bashundhara, and the massive satellite township of Purbachal. The land is held under 99‑year leases, and the original lease deed, signed by the RAJUK Chairman and the allottee, is the foundational title document.
RAJUK's role in land transactions:
| Function | Description |
|---|---|
| Sale Permission | Any sale, sub‑lease, or transfer of a RAJUK leasehold plot requires the prior written permission of the RAJUK Chairman. A Saf Kabala registered without this permission is voidable, and RAJUK may cancel the lease. |
| Transfer Fee | RAJUK charges a transfer permission fee, calculated as a percentage (typically 2%–5%) of the market value of the plot, as assessed by RAJUK's own Valuation Committee. |
| Building Plan Approval | No construction can commence on a RAJUK plot without an approved building plan, which is issued only after verifying the ownership and the zoning classification under the Detailed Area Plan (DAP). |
| Lease Renewal and Conversion | RAJUK processes applications for the renewal of expired leases and the conversion of leasehold to freehold (under periodic government policies). |
| Layout Plan Approval for Developers | Developers must obtain RAJUK's approval of the layout plan of a subdivision before selling individual plots. A deed for a plot not in an approved layout is void. |
The Chittagong Development Authority (CDA) was established under the Chittagong Development Authority Ordinance, 1959. It controls the leasehold estates of Agrabad, Khulshi, Nasirabad, Panchlaish, and other planned areas of the port city.
The CDA lease deeds contain a distinctive clause: a pre‑emptive right of the CDA to purchase the plot if the allottee wishes to sell. The CDA must be offered the plot at its assessed value before it can be sold to a third party. The CDA issues a Clearance Certificate if it declines to purchase.
The Khulna Development Authority (KDA), established under the Khulna Development Authority Ordinance, 1961, operates on similar lines to RAJUK, with transfer permission fees and building plan approval. KDA additionally imposes restrictions on construction near the river Rupsha and the coastal embankments.
The Rajshahi Development Authority (RDA), under the Rajshahi Town Development Authority Ordinance, 1976, administers leasehold plots. RDA's transfer fee is relatively lower, and it enforces a rule that no parcel less than 2 kathas can be subdivided, reflecting the lower population density of the city.
6. The Wakf Administrator and Minority Trusts
The Administrator of Wakfs (Wākpha Praśāsaka) is a statutory officer appointed under the Wakf Ordinance, 1962 (Ordinance No. I of 1962), under the Ministry of Religious Affairs. The Administrator supervises all Wakf properties in Bangladesh—mosques, madrasas, shrines (mazars), graveyards, and family wakfs (wakf‑alal‑aulad).
The Administrator maintains a Central Register of Wakfs in Dhaka, with district‑level registers maintained by the Deputy Administrator of Wakfs.
The Administrator's powers relevant to land transactions:
| Power | Description |
|---|---|
| Sanction for Sale | A Mutawalli (trustee of the Wakf) cannot sell, mortgage, or exchange Wakf property without the prior sanction of the Administrator. The Administrator will grant sanction only if the sale is manifestly in the interest of the Wakf—for example, raising funds for the repair of a mosque, or selling dilapidated property to purchase a more productive one. |
| Registration and Investigation | All Wakf properties must be registered with the Administrator. The Administrator may investigate the accounts of any Wakf and remove a Mutawalli for misfeasance. |
| Litigation | The Administrator may file suits for the recovery of Wakf property alienated without sanction and may defend suits against the Wakf. |
A buyer who encounters the word "Wakf" anywhere in the chain of title must conduct a search at the Administrator's office and obtain a Wakf Non‑Encumbrance Certificate. A sale by a Mutawalli without the Administrator's sanction is void, and the buyer acquires no title.
Under the Hindu Religious Welfare Trust Act, 2017, the Hindu Religious Welfare Trust (under the Ministry of Religious Affairs) supervises Debuttar properties (properties dedicated to a Hindu deity) and the Sebait (the trustee of the Debuttar).
The Sebait, like the Mutawalli, has limited powers of alienation and may sell only under legal necessity, with the sanction of the Trust. A search of the Trust's register is an essential due diligence step for any property that may be Debuttar.
Christian missionary properties (churches, schools, hospitals) are often held by the Diocese or the Mission Trust Association, registered under the Societies Registration Act, 1860, or the Trusts Act, 1882. The Trust Deed governs the conditions of sale.
Buddhist temple lands in the CHT and Cox's Bazar are managed by the temple management committee and are subject to customary Buddhist law and the CHT Regulation, 1900.
7. The Survey and Settlement Directorate
The Directorate of Land Records and Survey (DLRS) (Bhūmi Rēkarḍa ō Jaripa Adhidaptara), under the Ministry of Land, is the custodian of the nation's survey records. The DLRS conducts the BS/City Jorip surveys, maintains the central archive of CS, SA, RS, and BS maps and Khatians, and provides the technical personnel for the Land Survey Tribunal and for the Kanungo offices.
The Settlement Officer (Sēṭalamēnṭa Aphisāra) is a DLRS officer who conducts the settlement operations in a specific area during a survey. During the settlement, the Settlement Officer exercises quasi‑judicial powers to decide objections and to finally publish the Khatian.
The Director of Survey is the technical head of the DLRS, responsible for the geodetic standards, the aerial photography, the GNSS network, and the digital mapping programme.
8. Coordination Mechanisms and Institutional Reform
Recognising the chronic problems caused by the bifurcation of land administration, the government has initiated several coordination and reform measures:
The National Land Portal is the flagship integration project. It aggregates data from the AC Land offices (E‑Namjari, E‑Khajna), the Sub‑Registry offices (E‑Registry, where operational), the DLRS (digital Khatians and maps), and the Election Commission (NID database). The goal is a unified platform where a citizen can view the complete land record—deed, Khatian, map, Khajna status—for any Dag, in real time.
The integration is a work in progress; the E‑Registry component is not yet operational in all Sub‑Registry offices.
The toll‑free call centre, 16122, provides a single point of contact for citizens to inquire about the status of their mutation application, to report corruption, and to seek guidance. The call centre is linked to the Ministry's central monitoring cell and has proven effective in resolving cases of deliberate delay.
The Ministry of Land, in consultation with the Ministry of Law, has been working on a draft Unified Land Administration Act that would merge the functions of the Sub‑Registrar and the AC Land into a single Land Administration Officer at the Upazila level, who would be responsible for both the registration of deeds and the updating of the Khatian. This would eliminate the institutional gap that fraudsters exploit.
The draft Act is pending Cabinet approval and parliamentary enactment. If passed, it would be the most significant reform of the land administration since the State Acquisition and Tenancy Act, 1950.
Chapter References and Further Reading
For comprehensive understanding of Bangladesh's land administration infrastructure, the following resources provide authoritative information:
- State Acquisition and Tenancy Act, 1950 – Sections 40, 50, 90, 96, 144, 144A.
- Registration Act, 1908 – Sections 25, 28, 33, 35, 52, 71–76.
- Wakf Ordinance, 1962 – Sections 50–55.
- Vested Property Return Act, 2001 – Sections 3–8.
- Town Improvement Act, 1953 – Sections 50–60.
- Chittagong Development Authority Ordinance, 1959.
- Khulna Development Authority Ordinance, 1961.
- Land Development Tax Ordinance, 1976.
- Land Reforms Ordinance, 1984.
- Land Revenue Rules, 2025.
- Registration Rules, 1925 (as amended).
- Shaukat Mahmud, The Law of Transfer of Property in Bangladesh (Mullick Brothers, 2020), Chapter 2: "Institutional Framework."
- Mohammad Hossain, Land Laws of Bangladesh (Kamrul Book House, 2019), Chapter 3: "Revenue Administration."
- Ministry of Land, Bangladesh Land Record Digitisation Policy, 2015.
- Ministry of Land – Official Website
- Directorate of Registration – Official Website
- DLRS – Official Website
- RAJUK – Official Portal
- National Land Portal
How to Cite This Chapter (APA Style)
Suggested Citation:
Afzal Hosen Mandal. (2026). Chapter 3: Land Administration Infrastructure – Institutions and Officers. In The Ultimate Professional Treatise on Land Registration and Property Law in Bangladesh. Retrieved from https://afzaltipu.blogspot.com/2026/05/land-administration-infrastructure-institutions-officers.html
📖 Part I: The Historical and Technical Foundations of Land Records
Next: Chapter 4 – The Development of Land Survey Science in Bangladesh
Explore the evolution of land survey science in Bangladesh from the Great Trigonometrical Survey through CS, SA, RS, and BS surveys to modern GNSS/GIS digital cadastre. Essential for understanding Khatian accuracy, map reading, and boundary dispute resolution.
About the Author | Afzal Hosen Mandal
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