Mutation entries in revenue records are for administrative and fiscal purposes only and do not confer title; succession must follow law, and concurrent findings of fact in second appeal cannot be disturbed absent perversity.

Headnote:(A) Code of Civil Procedure, 1908 - Section 100 - Second Appeal - Scope of interference - Concurrent findings of fact - Perversity - It is well established that entries in revenue records, including mutation proceedings, are maintained for administrative convenience and for the purpose of assessment and collection of land revenue. In the absence of a valid and legally enforceable document of title, mutation entries alone cannot form the basis of ownership, and no right, title, or interest in immovable property can be claimed solely on the strength of such entries. (Para 16)

(B) Code of Civil Procedure, 1908 - Section 100 - Second Appeal - Substantial question of law - The scope of interference in a Second Appeal under Section 100 of the Code of Civil Procedure is extremely limited. Interference is permissible only when the appeal involves a substantial question of law. Concurrent findings of fact recorded by both the Courts cannot be interfered with unless such findings are shown to be perverse, based on no evidence, or contrary to settled principles of law. Questions essentially relating to re-appreciation of evidence and challenge to concurrent findings of fact do not give rise to any substantial question of law. (Paras 18, 20)

Facts of the case:
The dispute concerned land originally owned by a common ancestor. The plaintiff, claiming through a brother of the recorded owner, sought declaration of title and possession against defendants who derived title through an aunt of the recorded owner. The plaintiff contended that after the death of the recorded owner, the property devolved upon his brother, not his aunt, and that the subsequent mutation in favour of the aunt was illegal. The defendants claimed title through various sale deeds based on the aunt's name and adverse possession. The trial court decreed the suit in favour of the plaintiff, holding that the mutation in favour of the aunt was illegal and the subsequent sale deeds were not binding. The first appellate court affirmed the trial court's decree. On second appeal by the defendants, the High Court dismissed the appeals, upholding the concurrent findings.

Findings of Court:
The evidence established that the suit land was originally lawfully owned by the recorded owner, and the subsequent mutation in favour of the aunt in 1987 was not supported by any valid legal document and was therefore illegal. As the recorded owner had attained majority at the time of his death, succession ought to have devolved upon his lawful heirs, particularly his brother, rather than his aunt. Consequently, the aunt did not acquire any valid title, and any subsequent sale deeds based on her name are not binding. The concurrent findings of fact were based on evidence and not shown to be perverse.

Issues: 1. Whether a mutation entry in revenue records confers valid title to immovable property? 2. Whether the concurrent findings of fact by the courts below warrant interference in second appeal under Section 100 CPC?

Ratio Decidendi: Mutation entries in revenue records are for fiscal purposes and do not create or extinguish title. Succession to property must be in accordance with applicable law of succession; a mutation entry in favour of a person not entitled to succeed is illegal and confers no title. In second appeal, concurrent findings of fact cannot be disturbed unless perverse or based on no evidence; re-appreciation of evidence is not permissible. Result : Appeals dismissed.

Table of Content
1. consolidation of appeals against common judgment (Para 1 , 2 , 3)

Yogeswar Raj Singh S/o Vishwa Raj Singh, Aged About 50 Years R/o Raj Mahal, Police Station And Tahsil Kawardha, District Kabirdham, Chhattisgarh ....................Defendant No.15 --- Appellant

versus

1 - Narayan Prasad Shukla (Died And Deleted) As Per Honble Court Order Dated 07-04-2025 And 22-01-2026.

2 - Vikas Kumar S/o Narayan Prasad, Aged About 21 Years S/o Late Kapil Merawi, R/o Police Line Bilaspur, Chhattisgarh

3 - Kumari Radhika D/o Narayan Prasad, Aged About 25 Years D/o Late Kapil Merawi, R/o Police Line Bilaspur, Chhattisgarh ....................Plaintiffs

4 - Bharat S/o Peela Singh Gond, Aged About 44 Years R/o Village Mathpara, Ward No.8, Kawardha, Chhattisgarh, District : Kawardha (Kabirdham), Chhattisgarh

5 - Shatrughan S/o Peela Singh Gond, Aged About 39 Years R/o Village Mathpara, Ward No.8, Kawardha, Chhattisgarh

6 - Bhaktin D/o Late Peela Singh Gond, Aged About 64 Years R/o Village Mathpara, Ward No.8, Kawardha, Chhattisgarh

7 - Shanti Bai D/o Peela Singh Gond, Aged About 59 Years R/o Village Dhorli, Tahsil Kawardha, District Kabirdham, Chhattisgarh, District : Kawardha (Kabirdham), Chhattisgarh

8 - Arjun Singh S/o Bhagat Gond, Aged About 26 Years R/o Village Mathpara, District Kabirdham, Chhattisgarh, District : Kawardha (Kabirdham), Chhattisgarh

9 - Anusuiya Bai D/o Bhagat Gond, Aged About 34 Years R/o Khaijhiti, Tahsil Kawardha, District Kabirdham, Chhattisgarh

10 - Purnima D/o Bhagat Gond, Aged About 29 Years R/o Village Mathpara Ward No.08, Kawardha, Chhattisgarh

11 - Baishakhin Bai Wd/o Bhagat Singh, Aged About 59 Years R/o Village Mathpara, Ward No.8, Kawardha, Chhattisgarh

12 - Kaniya Singh S/o Jhangal Singh Gond, Aged About 59 Years R/o Village Khairjhiti, Tahsil Kawardha, District Kabirdham, Chhattisgarh

13 - Smt. Shashiprabha Devi (Died And Deleted) As Per Honble Court Order Dated 07-04-2025 And 22-01-2026.

14 - Smt. Manjari Devi W/o Rudra Dev Singh, Aged About 49 Years D/o Late Vishwa Raj Singh, R/o Tikamgarh, Madhya Pradesh

15 - Smt. Twarika Devi @ Vasudhara W/o Sanjay Singh, Aged About 44 Years D/o Late Vishwa Raj Singh, R/o Bisahu Palace Hotel, Chandpol Gate, Jaipur Rajasthan

16 - Ashwani Kumar Dubey S/o Dina Nath Dubey, Aged About 44 Years R/o Main Road, Malviya Nagar, Durg, District Durg, Chhattisgarh

17 - Naresh Chandravanshi (Died Through Lrs.) As Per Honble Court Order Dated 07-04-2025 And 22-01-2026.

17.1 - Padma Chandravanshi W/o Late Naresh Chandravanshi R/o Village Mathpara, Kawardha, Tahsil- Kawardha, District Kabirdham C.G.

17.2 - Dr. Swati Chandravanshi D/o Late Naresh Chandravanshi R/o Village Mathpara, Kawardha, Tahsil- Kawardha, District Kabirdham C.G.

17.3 - Piyush Chandravanshi S/o Late Naresh Chandravanshi R/o Village Mathpara, Kawardha, Tahsil- Kawardha, District Kabirdham C.G.

17.4 - Prafulla Chandravanshi S/o Late Naresh Chandravanshi R/o Village Mathpara, Kawardha, Tahsil- Kawardha, District Kabirdham C.G.

18 - Dheeraj Prasad S/o B.M.Brahman, R/o Raj Mahal Chowk, Kawardha, Tahsil Kawardha, District Kabirdham, Chhattisgarh

19 - Smt. Kausiliya Bai Wd/o Kanwal Singh, Aged About 63 Years R/o Village Police Line, Bilaspur, District Bilaspur, Chhattisgarh

20 - State Of Chhattisgarh, Through District Collector, Kabirdham, District Kabirdham, Chhattisgarh ....................Defendants

--- Respondents

SA No. 418 of 2017

1 - Bharat S/o Peela Singh Gond, Aged About 44 Years R/o Village Mathpara, Ward No.8, Tahsil Kawardha, District Kabirdham, Chhattisgarh ....................Defendant, Chhattisgarh ---Appellant

Versus

1 - Narayan Prasad (Died And Deleted) S/o Kapila Maravi, Aged About 56 Years R/o Police Line, Bilaspur, District Bilaspur, Chhattisgarh, Chhattisgarh, Chhattisgarh

2 - Vikas Kumar S/o Narayan Prasad, Aged About 21 Years R/o Police Line, Bilaspur, District Bilaspur, Chhattisgarh, District : Bilaspur, Chhattisgarh

3 - Ku. Radhika D/o Narayan Prasad, Aged About 25 Years R/o Police Lin

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2026 Supreme(Online)(Chh) 8630

IN THE HIGH COURT OF CHHATTISGARH AT BILASPURYogeswar Raj Singh – AppellantVersusNarayan Prasad Shukla – RespondentSA No. 307 of 2017 | SA No. 418 of 2017 | SA No. 396 of 2017

Mutation entries in revenue records are for administrative and fiscal purposes only and do not confer title; succession must follow law, and concurrent findings of fact in second appeal cannot be disturbed absent perversity.

Cases Referred (1)

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Yogeswar Raj Singh – Appellant
Versus
Narayan Prasad Shukla – Respondent
SA No. 307 of 2017 | SA No. 418 of 2017 | SA No. 396 of 2017