MP High Court: revenue record entries don't confer title, and a belated suo motu revision cannot revive a time-barred appeal

The High Court of Madhya Pradesh at Indore dismissed a writ petition by the State of Madhya Pradesh against an order of the Board of Revenue that had restored three private respondents as recorded cultivators (Adhipati Krishak) of land otherwise entered as belonging to a temple deity in Jhabua district. In 2003-04, a Sub-Divisional Officer and the Additional Collector had both ruled in the respondents' favour, and the State never appealed those orders. Years later, acting on a complaint routed through the Divisional Commissioner, the Additional Commissioner reopened the matter in a suo motu revision and reversed those unchallenged orders.

Justice Sandeep N. Bhatt held that the Board of Revenue was right to quash this suo motu revision under Section 50 of the Madhya Pradesh Land Revenue Code, 1959, because it revived a question that had attained finality once the State let the limitation period for appeal or revision lapse; a revisional power cannot be used to do indirectly, through a belated suo motu enquiry, what could not be done directly by a time-barred appeal. Following the Supreme Court's ruling in Suraj Bhan v. Financial Commissioner, the Court also held that an entry in revenue records serves only a fiscal purpose, payment of land revenue, and does not by itself confer or extinguish title, which only a civil court can finally decide. Noting the limited scope of supervisory jurisdiction under Articles 226 and 227 of the Constitution, the Court found no illegality in the Board's order and dismissed the petition.