The jurisdiction under Section 15(b) of the Odisha Survey and Settlement Act is limited to correcting entries in the Record of Rights and does not extend to adjudicating title or validity of registered sale deeds.

JUDGMENT :

SASHIKANTA MISHRA, J.

The petitioners seek to challenge the order dated 12.07.2024 passed by the Additional Commissioner, Additional Revision Court No. IV, Bhubaneswar in O.S.S. Case No. 1138 of 2023, whereby, the revision petition filed by them under Section 15(b) of the Odisha Survey and Settlement Act, 1958 was dismissed as not maintainable.

2. The facts of the case, briefly stated, are that the suit land originally stood recorded in the name of one Gadadhar Pradhan in the Sabik Record of Rights (ROR). Upon his death, the property devolved upon his legal heirs, namely, his wife, Uttam Bewa and daughter, Palei Dei. Uttam Bewa acting for the legal necessity of the family, transferred the entire suit land measuring Ac.0.250 decimals in favour of the petitioners by means of a registered sale deed bearing No. 5057 dated 11.09.1985 for consideration and delivered possession thereof. It is contended that ever since such purchase, the petitioners have been in peaceful possession and enjoyment of the suit land as rightful owners.

3. While the matter stood thus, Palei Dei, the daughter of the original recorded tenant and co-sharer, without any authority and in derogation of the earlier transfer executed two registered sale deeds on 29.09.1999, vide Sale Deed No. 4020 and Sale Deed No. 4021, transferring the suit land in two equal halves in favour of third parties, namely Sitanshu Sekhar Choudhury (O.P No. 3) and Smt. Rama Panda (O.P No.4). Said purchasers subsequently transferred their respective portions of the suit land in favour of Ramesh Chandra Choudhury (O.P no.-5) by executing registered sale deeds dated 12.06.2007. Thereafter, Ramesh Chandra Choudhury, who is stated to be the Director of M/s Nrican Infra Pvt. Ltd., transferred the entire suit land in favour of the said company, i.e., Opposite Party No. 6, by way of a registered sale deed dated 23.06.2022. During the Hal Settlement operation, the ROR was finally published on 21.11.2013, wherein the suit land was recorded in the names of the subsequent purchasers, ignoring the prior purchase made by the petitioners. Upon coming to know about such recording and subsequent transactions, the petitioners filed the revision petition under Section 15(b) of the OSS Act seeking correction of the ROR.

4. The Revisional Authority upon due consideration dismissed the revision petition holding, inter alia, that it lacks jurisdiction to examine the validity of registered sale deeds and that the dispute raised involves adjudication of title which cannot be undertaken in a proceeding under Section 15(b) of the OSS Act. Said order is impugned in the present writ application.

5. Be it noted that despite service of notice, none appeared on behalf of the private Opposite Party Nos. 3, 5, and 6. This Court, by order dated 10.12.2025, held that service of notice upon them was sufficient on the basis of paper publication. Similarly, notice upon Opposite Party Nos. 2(a) and 4 were also held sufficient. However, none appeared on their behalf.

6. Heard Mr. B. Baug, learned Senior Counsel with Mr. G.R. Sahoo, learned counsel for the petitioners and Mr. S.N. Patnaik, learned Additional Government Advocate for the State.

7. Mr. Baug would argue that Revisional Authority has committed an error in dismissing the revision petition on the ground of maintainability. He submits that the petitioners had acquired right, title, and interest over the suit land on the basis of a registered sale deed dated 11.09.1985, much prior to the Hal Settlement operation and final publication of the ROR. He further submits that Revisional Authority failed to appreciate tha