विद्या देवी बनाम हिमाचल प्रदेश राज्य
| Citation | (1999) 2 SCC 4 |
| Court | Supreme Court of India |
| Date | 2 December 1998 |
| Year | 1999 |
| Bench | S.P. Bharucha, S. Rajendra Babu JJ. |
| Acts/Articles | Punjab Land Revenue Act Section 35, Transfer of Property Act |
| Category | Property & 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.
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.
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.
The definitive authority on the limited effect of mutation. Cited in countless land disputes in Haryana and Punjab where parties confuse mutation with title.
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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.