Change in revenue record doesn't create, end property title: SC

The Supreme Court has ruled that a property title cannot be determined solely based on its entry in revenue records. A bench of Justices Sanjay Karol and Augustine George Masih dismissed an order from the Madhya Pradesh High Court that had based a title dispute on the revenue record. The court emphasized that a property right cannot be considered as voluntarily abandoned due to a revenue entry in favor of another party; such a declaration must be independently proven by the party relying on it.

The bench stated that an entry in the revenue record is not a creation or extinguishment of title and is meant for fiscal purposes only. The court's order from a tehsildar (revenue official) may regulate the revenue record, but it does not convey ownership or relinquishment of property rights. The court further explained that the statutory presumption of correctness attached to a revenue entry under the MP Land Revenue Code is merely a rebuttable evidentiary presumption and not a presumption of title itself.

The mutation of a property in the revenue record does not create, end, or have any presumptive value for the title; it only enables the person in whose favor mutation is ordered to pay the applicable land revenue. The court also clarified that the time limit for filing a title dispute cannot begin from the date of the revenue entry alone.