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2026 Supreme(Online)(Mad) 42059

IN THE HIGH COURT OF JUDICATURE AT MADRAS
M. Dhandapani, J
Akilan – Appellant
Versus
District Revenue Officer – Respondent
W.M.P. Nos.19040, 19041 and 19042 of 2026



Advocates:
For the Appellants/Petitioners: K. Venkatesan
For the Respondents: D. Ravichander

Revenue authorities lack the jurisdiction to adjudicate disputed questions of title to immovable property, and any mutation of revenue records remains subject to the outcome of pending civil court proceedings.

Headnote:The petitioner filed a writ petition challenging the order passed by the District Revenue Officer regarding the transfer of Patta and correction of revenue records in a land dispute, asserting that the authority lacked jurisdiction to decide title disputes. The respondent argued that the order was passed based on existing materials and that the petitioner had alternative remedies. The court examined the relevant laws regarding the scope of revenue jurisdictions and found that the revenue authorities cannot adjudicate disputed questions of title. The main issue was whether the revenue authorities possess the power to determine title to immovable property while a civil suit is pending between the parties. The court reasoned that since a title dispute is already sub judice before the competent Civil Court, the revenue authority's interference through the impugned order was unsustainable, reiterating that any mutation in revenue records is subject to the final decree of a Civil Court. The writ petition is disposed of, and the impugned order is set aside with liberty to the parties to work out their rights in the pending civil litigation.

Table of Content
1. revenue authorities can only correct records where title is not in dispute. (Para 2 , 3 , 4 , 5)
2. pending civil suits preclude revenue authorities from issuing orders on title. (Para 6 , 7 , 8 , 9)
3. court disposes of writ, relegated parties to civil court. (Para 10 , 11)

ORDER

Mr.D. Ravichander, learned Special Government Pleader takes notice for respondents 1 to 3. By consent of both the parties, this writ petition is taken up for final disposal at the admission stage itself.

2. Challenging the proceedings of the 1st respondent in No.13096/2024/A1 dated 18.02.2026, whereby directions were issued for transfer of Patta and correction of revenue records in respect of the land comprised in Survey No.152/5A measuring 0.24 acres situated at Adichapuram Village in favour of the 4th respondent, this writ petition has been filed.

3. It is stated that the subject property originally belonged to the petitioner’s maternal grandfather, late Mr. L. Kunjuthevar, who had executed a registered Settlement Deed dated 17.02.1971 in favour of the petitioner’s mother, Smt. Anjammal. Thereafter, the property devolved upon the petitioner by way of a registered Release Deed dated 11.07.2019. According to the petitioner, himself and his predecessor-in-title have been in continuous possession and enjoyment of the property for more than 54 years and are cultivating the same.

4. It is further stated that the 4th respondent had earlier approached the Revenue Divisional Officer, Mannargudi, seeking correction of the survey sub- division number in the revenue records. The said request was considered and rejected by the Revenue Divisional Officer by order dated 08.10.2024, confirming the petitioner’s mother’s name in the Patta relating to Survey No.152/5A. Aggrieved by the same, the 4th respondent preferred a revision before the 1st respondent after a delay of more than 210 days, beyond the prescribed period of limitation.

5. It is the case of the petitioner that the 1st respondent, without conducting any enquiry, without jurisdiction to adjudicate disputed title, and in complete disregard of the concurrent findings rendered by the 2nd and 3rd respondents, passed the impugned order directing transfer of patta in favour of the 4th respondent. Aggrieved by the said order dated 18.02.2026 issued by the

1st respondent, this writ petition has been filed.

6. Learned counsel for the petitioner submitted that without jurisdiction, the respondents decided disputed title in respect of immovable property and corrected revenue records. He vehemently argued that the 1st respondent in complete disregard of the concurrent findings, without conducting proper inquiry or without valid legal reasons passed the impugned order, which is unsustainable and illegal. He further contended that the impugned proceedings were passed in violation of the principles of natural justice and despite the specific intimation regarding the pendency of O.S.No.57 of 2025 on the file of the District Munsif Court, Mannargudi, wherein the very same issue relating to title and possession is the subject matter of adjudication. He strongly pointed out that the revenue authorities have no jurisdiction to decide title disputes relating to immovable property, which domain exclusively falls within the jurisdiction of the competent Civil Court. In view of the above, the impugned order issued by the 1st respondent dated 18.02.2026 is bad in law and therefore, the same is liable to be set aside as well as he prayed to declare the petitioner as the lawful patta-holder.

7. Per contra, learned Special Government Pleader appearing for the respondents 1 to 3 submitted that the impugned order has been passed by the 1st respondent/competent authority based on the materials available on record and after considering the rival claims made by the parties. He further submitted that the proceedings related only to correction of revenue records and do not finally adjudicate title. He also submitted that the p

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