बलराम कुमावत बनाम भारत संघ
| Citation | (2003) 7 SCC 628 |
| Court | Supreme Court of India |
| Date | 11 August 2003 |
| Year | 2003 |
| Bench | Doraiswamy Raju, Arijit Pasayat JJ. |
| Acts/Articles | Punjab Land Revenue Act, Transfer of Property Act |
| Category | Property & Land Law |
Key Principle Established
Mutation in revenue records does not create or extinguish title. It is merely a fiscal/administrative process for revenue collection and has no bearing on ownership rights.
A dispute arose regarding whether mutation entries in revenue records (jamabandi/khasra) confer any title or ownership rights on the person in whose name mutation is recorded.
The Court held emphatically that mutation in revenue records does not create or extinguish title. Mutation is a fiscal process — its purpose is to ensure that land revenue is collected from the right person. It is not proof of ownership and cannot be relied upon as evidence of title. Title can only be established by a registered deed, court decree, or other valid instrument of transfer.
This is the most cited judgment on the limited effect of revenue mutation. In Haryana and Punjab, where revenue records (jamabandi) are commonly treated as evidence of ownership, this judgment clarifies that mutation alone proves nothing about title. It is essential in every property dispute involving conflicting revenue entries.
(1999) 2 SCC 4
Mutation in revenue records does not confer title. It is merely a fiscal record for revenue collection purposes. Title can…
Read Analysis(2020) 9 SCC 1
Daughters have equal coparcenary rights by birth under the Hindu Succession (Amendment) Act, 2005 — irrespective of whether the father…
Read Analysis2010 SCC OnLine P&H 8312
Shamlat deh (village common land) cannot be sold, transferred, or encroached upon. Panchayat has duty to protect common land for…
Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.