Punjab & Haryana High Court, Chandigarh
Citation(1999) 2 SCC 4
CourtSupreme Court of India
Date2 December 1998
Year1999
BenchS.P. Bharucha, S. Rajendra Babu JJ.
Acts/ArticlesPunjab Land Revenue Act Section 35, Transfer of Property Act
CategoryProperty & Land Law

Key Principle Established

Mutation in revenue records does not confer title. It is merely a fiscal record for revenue collection purposes. Title can only be determined by a competent civil court.

Brief Facts

A dispute where one party relied on mutation entries in revenue records to claim ownership of land, while the other party held a registered sale deed.

Ratio Decidendi

The Court held that mutation in revenue records is merely a fiscal formality for purposes of revenue collection. It does not confer, extinguish, or prove title. Only a competent civil court can determine title to immovable property. Revenue authorities have no jurisdiction over title disputes.

Impact & Significance

The definitive authority on the limited effect of mutation. Cited in countless land disputes in Haryana and Punjab where parties confuse mutation with title.

Tags & Related Topics

Property & Land Law Punjab Land Revenue Act Section 35 Transfer of Property Act
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Disclaimer

This 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).

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