A subsequent purchaser may claim the benefit of a vendor’s successful challenge to revenue proceedings.

The subject land was granted to Guruva Bovi in 1960 and dealt with in 1970.

Resumption proceedings initiated by members of the grantee’s family resulted in orders by the Assistant Commissioner and Deputy Commissioner in 2007 and 2008.

In an earlier writ petition, W.P. No. 1897 of 2009, the High Court quashed those orders on 13 March 2020; the petitioner’s vendor had been a party to that proceeding, but the petitioner, a subsequent purchaser, had not.

Revenue authorities declined to enter the petitioner’s name in the records because he was not a party to the earlier writ proceeding.

The petitioner sought to challenge the 2007 and 2008 orders and obtain the benefit of the earlier decision.

1. Whether a subsequent purchaser from a party to an earlier writ proceeding may claim the benefit of the High Court’s order quashing the revenue orders, despite not having been a party himself

2. Whether the revenue authorities could refuse to enter the petitioner’s name in the revenue records solely because he was not a party to the earlier writ proceeding

The Court relied on its order in W.P. No. 1897 of 2009, which had quashed the Assistant Commissioner’s and Deputy Commissioner’s orders.

It held that the benefit of that order could be claimed by a subsequent purchaser from a party to the earlier proceedings.

The judgment cited no statute or other precedent as the basis for this conclusion.

The Court noted that the petitioner’s vendor had participated in the earlier proceedings and that the orders underlying the revenue authorities’ refusal had already been quashed.

As a subsequent purchaser from that party, the petitioner was entitled to claim the benefit of the earlier order.

Accordingly, the authorities’ refusal, based solely on the petitioner’s absence from the earlier writ proceeding, could not be sustained.

It disposed of the petition without quashing the 2007 and 2008 orders again, as they had already been quashed, and directed the revenue authorities to take steps in accordance with law to enter the petitioner’s name in the revenue records within four weeks of receiving a copy of the order.