Entries In Revenue Records Do Not Confer Title To A Property: SC [Read Judgment]

The Supreme Court on October 16, 2019, in the case of Prahlad Pradhan & Ors. v.  Sonu Kumhar & Ors., has held that the entries in the revenue records do not confer title to a property, nor do they have any presumptive value on the title.

The Division Bench comprising of Justice Indu Malhotra and Justice Krishna Murari noted that such entries only enable the person in whose favour mutation is recorded, to pay the land revenue in respect of the land in question.

The court was hearing a civil appeal wherein the contention raised by the appellants was that since Mangal Kumhar (predecessor) was the recorded tenant in the suit property as per the Survey Settlement of 1964, the suit property was his self-acquired property.

Rejecting the said contention, the court observed that "The said contention is legally misconceived since entries in the revenue records do not confer title to a property, nor do they have any presumptive value on the title. They only enable the person in whose favour mutation is recorded, to pay the land revenue in respect of the land in question. As a consequence, merely because Mangal Kumhar's name was recorded in the Survey Settlement of 1964 as a recorded tenant in the suit property, it would not make him the sole and exclusive owner of the suit property.”

Since the appellants failed to adduce any evidence whatsoever, apart from the Survey Settlement of 1964 to establish that the suit property was the self­acquired property of Mangal Kumhar, the bench dismissed the appeal.

[Read Judgment]