Revenue Record Entries Do Not Confer Title To A Property, Reiterates SC [Read Judgment]

The Supreme Court has reiterated 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 bench comprising 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.

In Prahlad Pradhan vs. Sonu Kumhar, the contention raised by one party was that since his predecessor (Mangal Kumhar)name was the recorded tenant in the suit property as per the Survey Settlement of 1964, the suit property was his selfacquired property. Rejecting the said contention, the bench observed: 

"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.2 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".

The Court mainly referred to the judgment in Sawarni (Smt.) v. Inder Kaur, (1996) 6 SCC 223.

The bench then dismissed the appeal holding that the appellant failed to adduce any evidence whatsoever, apart from the Survey Settlement of 1964 to establish that the suit property was the self¬acquired property of Mangal Kumhar. 

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