Searching Case Laws & Precedent on Legal Query.....!
Analysing the retrieved Case Laws
Scanned Judgements…!
Searching Case Laws & Precedent on Legal Query.....!
Analysing the retrieved Case Laws
Scanned Judgements…!
Circle Officer's Authority to Correct Panji - The main point is that a Circle Officer's endorsement on a copy of Khesara Panji or Panji does not automatically confer certification or authority to correct or authenticate the document. The endorsement certified to be true does not make the copy a certified copy under law, especially if the document is not sealed or paid for properly. Additionally, as per Sections 61 to 65 of the Evidence Act, transcription or endorsement without comparison with the original does not qualify as secondary evidence. The documents such as Panji or Khesara Panji need proper certification and verification by authorized officers to be considered valid and correct ["Md. Rustam VS State of Bihar - Patna"].
Limitations of Circle Officer's Corrections - The Court observed that corrections or endorsements made by a Circle Officer are not equivalent to legal certification, and such endorsements cannot be used to correct errors or establish authenticity of the original documents. For example, a copy endorsed by the Circle Officer without proper certification or sealed is not a certified copy and cannot be relied upon as conclusive evidence ["Md. Rustam VS State of Bihar - Patna"].
Jurisdiction and Legal Authority - The Court clarified that revenue authorities, including the Circle Officer, do not have the jurisdiction to examine the authenticity of documents like Sanshodhan Panji or Panji corrections related to ownership or mutation, which are subject to civil court proceedings or specific legal procedures. For instance, challenges to Sanshodhan Panji or mutation entries should be addressed in civil courts, not revenue courts or by Circle Officers through corrections ["Firoz Khan VS State of M. P. - Madhya Pradesh"], ["Firoz Khan vs The State Of Madhya Pradesh - Madhya Pradesh"], ["Jahar Singh Gurjar vs The State Of Madhya Pradesh - Madhya Pradesh"].
Conclusion - The Circle Officer does not have the right or authority to correct or certify the correctness of Panji or Khesara Panji documents. Such corrections require proper certification, legal authority, and should be verified through appropriate legal channels. Endorsements or corrections by a Circle Officer alone are insufficient to establish the authenticity or correctness of these documents under law ["Md. Rustam VS State of Bihar - Patna"].
References:- ["Md. Rustam VS State of Bihar - Patna"]- ["Firoz Khan VS State of M. P. - Madhya Pradesh"]- ["Firoz Khan vs The State Of Madhya Pradesh - Madhya Pradesh"]- ["Jahar Singh Gurjar vs The State Of Madhya Pradesh - Madhya Pradesh"]
Land revenue records play a crucial role in property ownership, taxation, and disputes in India, particularly in states like Bihar where documents such as Panji 2 (often referring to Khesra Panji or field registers) are integral. But what happens when errors appear in these records? A common question arises: whether the circle officer has the right to correct Panji 2 or not.
This blog post dives deep into the legal framework governing corrections to revenue records like Panji 2. We'll explore the circle officer's authority, limitations, key court judgments, and practical recommendations. Whether you're a landowner, farmer, or legal professional, understanding these nuances can prevent costly litigation.
Panji 2, also known as Khesra Panji in Bihar's land revenue system, is part of the Record of Rights maintained post-survey and settlement operations. It details plot-specific information like khasra numbers, ownership, and cultivation data. Errors in these records—clerical, arithmetical, or due to oversight during preparation—can lead to disputes over possession, rent, or taxes.
Revenue records are administrative tools for land revenue collection, not conclusive proof of title. As courts have repeatedly emphasized, corrections to such records do not confer or extinguish substantive rights. Ashpati Kunwar VS State of Jharkhand through Deputy Commissioner, Garhwa - 2019 0 Supreme(Jhk) 1996
Generally, circle officers (or equivalent revenue officers like Land Record Officers) have the authority to correct revenue records, including Panji 2, after survey and settlement operations are complete. This power stems from specific provisions in land revenue acts, such as Section 136 of the relevant Bihar Land Reforms Act.
The primary purpose is to rectify clerical errors or mistakes that crept in during record preparation. For instance, in a key ruling, the court held that the Land Record Officer has jurisdiction under Section 136 of the Act to correct errors in the Record of Rights of the Annual Register after settlement or survey operations are over. Poosa Ram VS Board of Revenue - 1995 0 Supreme(Raj) 523
Similarly, another decision affirmed: the power to correct entries in revenue records, including Panji 2, exists after the completion of survey and settlement, and the officer can do so to rectify mistakes. Khyali VS State of Rajasthan - 1995 0 Supreme(Raj) 982
This authority is administrative, ensuring records accurately reflect factual data for revenue purposes.
While circle officers can correct Panji 2, their power is strictly confined to clerical or apparent errors. They lack jurisdiction over substantive issues like title, possession, or tenancy rights, which require civil courts.
The court clarified: the authority of the revenue officer to make corrections is limited to errors that have crept in during the record creation process. The officer does not have jurisdiction to decide on rights, titles, or substantive disputes. Ashpati Kunwar VS State of Jharkhand through Deputy Commissioner, Garhwa - 2019 0 Supreme(Jhk) 1996
In another case: mutation or correction of revenue records does not confer or extinguish rights and cannot be used as a substitute for a civil suit. Sudha Singh VS State of Jharkhand - 2018 0 Supreme(Jhk) 905
Several judgments reinforce these principles while touching on Panji corrections:
In a Darbhanga case, the Circle Officer made an endorsement on a copy of khesara panji, highlighting their role in public document custody and corrections. Md. Rustam vs The State of Bihar
Challenges to Sanshodhan Panji (amended registers) were appealed to Sub-Divisional Officers, indicating a hierarchy for corrections beyond circle level. Firoz Khan vs The State Of Madhya Pradesh
Verification issues in rent receipts linked to Panji entries led to inquiries by revenue staff reporting to Circle Officers. AJAY KUMAR THAKUR @ AJAY THAKUR Vs The State
Khesrawar Panji used for market value estimation was deemed unauthorized in stamp duty contexts, underscoring limits on record usage. Manju Dwivedi VS State of Bihar - 2023 Supreme(Pat) 967
In broader revenue contexts, Circle Officers correct records per Deputy Commissioner directions, e.g., reserving land as playground by updating entries. Polofield Sanmilita Unnayan Parishad represented by Sri Poldeep Saikia, Son of Late Mahesh Saikia VS State of Assam represented by the Commissioner and Secretary to the Govt. of Assam - 2011 Supreme(Gau) 52
These cases illustrate that while corrections are routine for errors, they must align with law and evidence.
If facing Panji 2 errors:1. Approach Circle Officer First: Submit application with evidence for clerical fixes. Ensure post-survey context.2. Document Everything: Maintain copies of old/new records, survey maps, and communications.3. Escalate if Needed: Appeal to Sub-Divisional Officer or Collector for disputes; civil suit for title issues.4. Avoid Self-Help: Don't rely on records alone for transactions—verify via mutation or title deeds.
Circle Officers should limit actions to clerical errors and refer substantive matters upward. Khyali VS State of Rajasthan - 1995 0 Supreme(Raj) 982
Navigating revenue record corrections like Panji 2 requires understanding the circle officer's narrow but vital authority. While they can fix clerical mistakes efficiently, complex disputes demand judicial intervention. This analysis draws from established precedents—consult a local legal expert for case-specific advice, as laws may vary by jurisdiction.
Disclaimer: This post provides general information based on cited judgments and is not legal advice. Always seek professional counsel for your situation.
References:1. Poosa Ram VS Board of Revenue - 1995 0 Supreme(Raj) 5232. Khyali VS State of Rajasthan - 1995 0 Supreme(Raj) 9823. Ashpati Kunwar VS State of Jharkhand through Deputy Commissioner, Garhwa - 2019 0 Supreme(Jhk) 19964. Sudha Singh VS State of Jharkhand - 2018 0 Supreme(Jhk) 9055. Other cases as noted.
#LandRecords #CircleOfficer #BiharRevenue
It would be evident from the record that the petitioner had filed a copy of Cadastral Survey Khesra Panji of Plot No. 143, 144 and 145 with endorsement of the Circle Officer “certified to be true”. However, the same was not issued on payment of legal fees and was also not sealed. ... Some endorsement by the Circle Officer on a copy of khesara panji “certified to be true” would not make the copy a certified copy. 17. At this stage, i....
Some endorsement by the Circle Officer on a copy of khesara panji Circle Officer, Sadar Darbhanga, District- Darbhanga. ... It provides that every public officer having the custody of a public document, which any person has a right to contended that the endorsement made by the Circle Officer on p style="position:absolute;white-space:pre;margin:0;
The petitioner challenged the Sanshodhan Panji by way of filing an appeal before the Sub Divisional Officer, Chourai. ... The re-producted part of the orders passed by the Sub-Divisional Officer prima facie appears to be beyond his jurisdiction. Learned counsel appearing for the petitioner is correct in submitting that S.D.O does not have any jurisdiction to examine the authenticity of Hiba. ... 2. The land bearing Khasara No.482/29 and 484/2, Patwari Halka No.30/65,....
The petitioner challenged the Sanshodhan Panji by way of filing an appeal before the Sub Divisional Officer, Chourai. ... Learned counsel appearing for the petitioner is correct in submitting that S.D.O does not have any jurisdiction to examine the authenticity of Hiba. ... 2. ... The land bearing Khasara No.482/29 and 484/2, Patwari Halka No.30/65, Bandobast No.80, situated at revenue circle Chand, District Chhindwara was owned and recorded in the name of one Safi....
The petitioner challenged the Sanshodhan Panji by way of filing an appeal before the Sub Divisional Officer, Chourai. ... Learned counsel appearing for the petitioner is correct in submitting that S.D.O does not have any jurisdiction to examine the authenticity of Hiba. ... 2. ... The land bearing Khasara No.482/29 and 484/2, Patwari Halka No.30/65, Bandobast No.80, situated at revenue circle Chand, District Chhindwara was owned and recorded in the name of one Safi....
The finding arrived at by the Circle Officer as well as the Collector, Samastipur that the land belongs to the railways was in absence of any valid evidence brought about to establish the right, title in favour of the railway authorities. ... The proceeding was held, rival positions of the parties were placed before the Circle Officer and an order dated 26.6.2006 came to be passed against the petitioners by the Circle Officer, Dalsingsarai, which is Annexure-7 to the ....
The petitioner challenged the Sanshodhan Panji by way of filing an appeal before the Sub Divisional Officer, Chourai. ... 2. ... No.30/65, Bandobast No.80, situated at revenue circle Chand, District counsel appearing for the petitioner is correct in submitting that S.D.O p style="position:absolute;white-space:pre;margin
correct. ... reason, this miss-conspection arose, which would appear from the report dated 31.10.2018 of Rajashwa Karamchari submitted to the Circle Officer, Bisfi, which is at page-31. ... Thereafter, on the compliant petition, inquiry was made and it was detected that the petitioner had submitted rent receipts in respect to Jamabandi No. 70 detailed in Panji No. 11, but on verification the entry was not found ... No.30515 of 2019(4) dt.16-07-2019 2/2....
2. ... It is also submitted that the registering officer can only consider the guideline register of estimated minimum value for determining the market value of the land, however the said Khesrawar Panji is prepared without any authority of law and estimation of market value on the said basis is wholly without ... The State of Bihar & Ors., reported in 2018 (2) PLJR 293, which the learned State counsel has not been able to refute. It would be apt to reproduce paragraphs no. 6 to 9 of the said judgment ....
... 2. ... ... (2) The charge shall then be read and explained to the accused, and he shall be asked whether he pleads guilty of the offence charged or claims to be tried.” ... 8. ... Therefore, the entry of the said registers be treated to be correct and on the basis of the entry made in the said two registers, on the date of incident, i.e., 20.3.2018, the prosecutrix was more than 18 years of age and as such charge under Section 4 of the POCSO Act is prima facie not made out. ... Fatehkaran Mehdu), i....
1. Whether the lower appellate Court is correct in reversing the decree and judgment of the trial Court? 2. Whether granting relief though prayed is correct or not? 11. Both Courts gave concurrent finding in respect of issue No.4 and held that suit is not barred by resjudicata on the ground that property shown in O.S.No.13 of 1983 and present suit schedule property are not one and the same.
Mr. Goswami, learned counsel on the other hand referring to the impugned order in the writ petition i.e. order dated 18.05.2017 passed by the Commissioner, GMC, Guwahati and relying the instructions received along with the connected affidavit filed by the GMC, submits that the GMC is not concerned in respect of the classification/category of the land under the possession of the petitioner nor the land under the possession of the respondent No. 7. Mr. Chouhan submits that though the said report of the Circle Officer was submitted in the court of learned Munsiff No. 2, Kamrup (M), ho....
The Circle Office held that Kurfa settlement in favour of the father of the plaintiff No. 1 was contrary to the provision of Santhal Parganas Tenancy Act without taking into consideration that at the time of the said settlement, the Act itself was not in existence and it was brought on statute book much thereafter. So far the order of the Circle Officer is concerned, the same has not declared any right and title. There was no question of contravention of any provision which was then not in existence. In that view, there was no necessity to add the State of Bihar as a defend....
In the objection filed by the Respondent, the total lorry load was shown as 14655 and the seigniorage has been calculated at Rs.250/- per load and thereby total loss to the Government caused has been shown as Rs.36,63,750/-. Till such time, it will be appropriate to direct them to deposit the present assessed value while considering the pre-arrest bail. I am also satisfied that the Petitioners will not tamper with witness or flee from justice and therefore, no prejudice would be caused to the prosecution if the Petitioners are granted Anticipatory Bail. Whether the Inspection Repor....
Sd/- Add. Deputy Commissioner, Sonitpur, Dated: 7-3-2007" (Emphasis supplied) As such lands measuring 9B 4K 2L covered by Dag No. 387 situated in Tezpur town 4th part reserved in the name of 'Polofield' shall be reserved as a play ground instead of allotment in the name of Tezpur District Cricket Association shall be used as a play ground as per directions of the Deputy Commissioner. The Circle Officer, Tezpur Revenue Circle shall correct the revenue records accordingly and report compliance.
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