Karnataka High Court
Property and Real Estate LawCivil Procedure and Evidence

A court may record a lawful compromise over land that never vested in the State.

SRI. IMAMASAB S/O RAJESAB KOTI, SINCE DECEASED BY HIS LRS. vs THE LAND TRIBUNAL

Karnataka High CourtJUDGMENT: September 25, 20262 MIN READSOURCE JUDGMENT
A court may record a lawful compromise over land that never vested in the State.. SRI. IMAMASAB S/O RAJESAB KOTI, SINCE DECEASED BY HIS LRS. vs THE LAND TRIBUNAL. Karnataka High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners, legal representatives of the original Form No. 7 applicant, challenged the Land Tribunal’s order dated 13 March 2026, which declined to modify its 1981 rejection of the application for occupancy rights over 10 acres 21 guntas in R.S. No. 45.

Source reference: p. 5, paras. 2, 4

The Tribunal had found that the land was under the owners’ self-cultivation.

Source reference: p. 5, paras. 2, 4

After the landowners sold the entire property to respondent No. 5 in 2024, the petitioners and respondents 2–5 entered into a compromise: respondent No. 5 would retain 6 acres, while the petitioners would receive the remaining 4 acres 21 guntas through a duly registered conveyance.

Source reference: pp. 5–8, compromise paras. 3–6

The parties sought the Court’s approval of the settlement.

Source reference: p. 8, compromise para. 9
02

Issues

1. Whether the parties’ compromise could be accepted and recorded in disposing of the writ petition.

Source reference: p. 4, para. 3; p. 10, para. 6

2. Whether the settlement affected any right or interest of the State or public authority so as to prevent the Court from recording it.

Source reference: p. 4, para. 3; p. 8, compromise para. 8
03

Law Applied

Order XXIII Rule 3 of the Code of Civil Procedure permits a court to record a lawful compromise between parties and dispose of the proceeding in accordance with its terms.

Source reference: p. 4, para. 1

The Court also exercised its writ jurisdiction under Articles 226 and 227 of the Constitution, under which it considered the parties’ settlement and whether it affected public or State interests.

Source reference: pp. 3–4; p. 8, compromise para. 8
04

Reasoning

The Court noted that the Tribunal had rejected the occupancy-rights claim on the basis that the land was under the owners’ self-cultivation and that the land had never vested in the Government; accordingly, it found no State interest created in the land that would make the compromise impermissible.

Source reference: p. 4, para. 3

The parties’ settlement resolved their competing claims, allocated the land between respondent No. 5 and the petitioners, and provided for a registered conveyance of the petitioners’ portion.

Source reference: pp. 6–8, compromise paras. 5–6

The Court therefore regarded the compromise as lawful and valid.

Source reference: p. 4, para. 3
05

Holding

The Court accepted and recorded the compromise and disposed of the writ petition on that basis; the compromise petition was made part of the order.

The parties were permitted to approach the competent revenue authorities to record their respective names in accordance with the settlement.

Source reference: p. 10, para. 7

The transfer of 4 acres 21 guntas to the petitioners remains subject to execution and registration of the conveyance as agreed.

Source reference: p. 7, compromise para. 6
Karnataka High Court

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SRI. IMAMASAB S/O RAJESAB KOTI, SINCE DECEASED BY HIS LRS.vsTHE LAND TRIBUNAL

Karnataka High Court · September 25, 2026

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