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Jitendra Singh v. State of Madhya Pradesh (Supreme Court, 2021)

A mutation entry does not confer title; it serves a fiscal purpose. Title disputes go to civil courts.

Court judgment / order6 Sep 2021

Read carefully. The facts arose under the Madhya Pradesh Land Revenue Code, so the procedure discussed is Madhya Pradesh's, not Haryana's. What is of general application is the Court's restatement of the settled principle about revenue entries, which it supported with earlier Supreme Court decisions.

Case note

Material facts
A mutation was sought on the basis of a will; the application was filed before the testator's death and the will was disputed. Revenue authorities ordered mutation; the High Court set that order aside.
Issue
Whether the High Court was right to set aside the mutation and relegate the claimant to a civil court.
What was decided
Relying on earlier decisions including Balwant Singh v. Daulat Singh (1997) and Suraj Bhan v. Financial Commissioner (2007), the Court restated that mutation entries do not confer right, title or interest and serve a fiscal purpose; a person claiming under a disputed will must establish rights in a competent civil court, after which mutation can follow.
Order / relief actually given
Special leave petition dismissed; the High Court's order stood.
Later proceedings
Not checked.