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2025 Supreme(Telangana) 925

IN THE HIGH COURT FOR THE STATE OF TELANGANA
MOUSHUMI BHATTACHARYA, GADI PRAVEEN KUMAR, JJ.
Salla Chandra Reddy - Appellant
Vs.
The State of Telangana - Respondent
Writ Petition Nos.7272 and 21577 of 2019
Decided On : 23-10-2025

Advocates:
Advocate Appeared:
For the Appellant : Sunkari Vamshi Krishna
For the Respondent: GP For Revenue (TG)

Unregistered agreements do not confer title; disputes regarding title and possession must be adjudicated by civil courts rather than administrative authorities.

Headnote:(A) Telangana Rights in Land and Pattadar Passbooks Act, 1971 - Section relating to jurisdiction of RDO and Tahsildar in mutation matters - Registration Act, 1908 - Sections 17 and 49 - The Court determines that unregistered agreements do not confer title, while asserting that effective resolution of title disputes lies exclusively with civil courts. (Paras 12, 35, 43)

(B) Principles of natural justice - Must show demonstrable prejudice for procedural issues to invalidate proceedings - Mere procedural irregularity is insufficient to void the action taken. (Paras 43, 44)

Facts of the case:
The case comprises of two writ petitions challenging an RDO order allowing certain parties to register their names for land mutation. Petitioners attribute title based on alleged unregistered agreements and a compromise decree. (Paras 4, 5, 12)

Findings of Court:
The Court declares both writ petitions meritless and directs the petitioners to pursue claims in civil courts before seeking remedies in writ jurisdiction. (Paras 47, 42)

Issues: The core questions pertain to the nature of the petitioners' rights to the disputed lands and whether the RDO acted within jurisdiction in the mutation proceedings. (Paras 4, 42)

Ratio Decidendi: The Court emphasizes that administrative bodies cannot adjudicate upon title disputes which must be resolved by competent civil courts, asserting that claims based on unregistered documents lack standing. (Paras 38, 40)

Result: Both writ petitions dismissed.

Table of Content
1. dispute over ownership and possession of agricultural lands (Para 2 , 4 , 5 , 6 , 10 , 11)
2. challenges to jurisdiction and claims of rights under past decrees (Para 12 , 13 , 14 , 15 , 17 , 18)
3. arguments on the validity of the compromise decree and legislative mandates (Para 19 , 20 , 21 , 22)
4. legal inadequacy of unregistered agreements to confer ownership (Para 24 , 25 , 26 , 27 , 33)
5. compromise decrees requiring registration to confer rights (Para 28 , 29 , 32 , 34)
6. judicial determination of title and possession issues reserved for civil court (Para 35 , 36 , 38 , 39 , 40)
7. refusal to adjudicate on title due to unresolved factual disputes (Para 44 , 46)
8. final order dismissing writ petitions and encouraging civil remedies (Para 47 , 48)

ORDER :

Gadi Praveen Kumar, J.

1. Since the issues raised in both the Writ Petitions arise out of the very same impugned proceeding Rc.No.B/145/2018 dated 20.02.2018, they are taken up together and are being disposed of by this common order.

2. The Writ Petitions, W.P.No.7272 of 2019 and W.P.No.21577 of 2019, are filed challenging the Proceedings Rc.No.B/145/2018 dated 20.02.2018 issued by the Revenue Divisional Officer (Respondent No.3/ “RDO”), by which the RDO directed the Tahsildar, Uppal Mandal (Respondent No.4), to mutate the names of respondent Nos.5 to 7 in the ‘occupation column’ in respect of lands admeasuring Ac.1-31 gts. in Sy.No.34; Ac.1-24 gtsin Sy. No.35; Ac.1-36 gts. in Sy. No.36; Ac.2-17 gts. in Sy. No.37 and Ac.2-23 gts. in Sy.No.39, situated at Uppal Kalsa Village, Uppal Mandal, Medchal–Malkajgiri District (erstwhile Ranga Reddy District).

3. We have elaborately heard Sri V.Ravinder Rao, learned Senior Counsel for Sri S.Vamshi Krishna, learned counsel for the petitioner inW.P.No.7272 of 2019, Sri Vivek Jain, learned senior counsel appearing for the petitioners in W.P.No.21577 of 2019, Sri B.Mayur Reddy, learned Senior Counsel representing Sri AtlaAbhinandhan Reddy, learned counsel appearing for respondent Nos.5 to 7 in both the Writ Petitions, Sri Kohir Bhaskar Reddy, learned counsel for respondent No.12 in W.P.No.21577 of 2019, Sri Md.Arshad Ahmed, learned counsel appearing for respondent No.13 in W.P.No.21577 of 2019 and Sri Dara Haritha Kiran, learned Assistant Government Pleader for Revenue in both the Writ Petitions.

4. The dispute concerns agricultural lands comprised in several survey numbers in UppalKalsa (Kalasa) Village, Uppal Mandal, Medchal– Malkajgiri District (erstwhile Ranga Reddy District). The controversy between the parties has been the subject of prolonged litigation before various fora.

5. The Petitioner in W.P.No.7272 of 2019, Mr. Salla Chandra Reddy, claims to be the owner and possessor of Acs.15-23 Gts. in Sy.Nos.34, 35, 36, 37, 39, 43, 44, 794 & 795, relying upon alleged Agreements of Sale dated 10-04-1971 and 12-04-1971 together with a compromise decree dated 13-08-1990 passed in I.A.No.887 of 1990 in O.S.No.231 of 1987 by the learned Additional Subordinate Judge, Ranga Reddy District. By virtue of the compromise decree dated 13-08-1990, the Petitioner claims title and possession to Acs.15-23 Gts.

6. The Petitioners in W.P.No.21577 of 2019 claim to be owners and possessors of another extent of Acs.15-23 Gts. in the same survey numbers, having succeeded to the lands from their ancestor, Late Sri Raja Malla Reddy, who purchased the lands by a registered sale deed.

7. Respondent Nos.5 to 7 asserts that originally Smt. Ashrafunnisa Begum was the pattadar and possessor of Acs.31.06 Gts. in the survey numbers in question. She sold the lands by a registered sale deed dated 20th Sherhwar 1354 Fasli (1944) to Sri Rokat Raman and Sri Venkat Reddy, who in turn sold the entire land by registered deed (Doc.No.195 of 1356 Fasli dated 10th 1356 Fasli (1946)) in favour of (i) Sri Raja Reddy, (ii) Sri Raj Malla Reddy (ancestor of Petitioners in W.P.No.21577 of 2019) and (iii) Sri Matham Lingaiah (father of Respondent Nos.5 to 7), jointly.

8. There

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