Challenges to phodi proceedings must be brought within the statutory three-year period.

The dispute concerned land in Sy. No. 173, Nelluru Village, which was phodi-subdivided in 1971.

The petitioners claimed through family partitions and subsequent revenue entries to hold land in the resulting subdivisions.

Respondent No. 5, who owned adjoining land that had been converted for non-agricultural use, alleged a measurement error in the phodi and challenged it.

The Deputy Director of Land Records rejected the challenge on 24 January 2025, but the Regional Joint Director allowed respondent No. 5’s revision on 6 November 2025.

The petitioners sought to quash that revisional order.

Whether the Regional Joint Director could interfere with the 1971 phodi after a delay of more than five decades.

Whether the alleged measurement error and disputed boundaries should be resolved in revenue proceedings or before a Civil Court.

Section 56(3) of the Karnataka Land Revenue Act, 1964 provides a three-year period for an aggrieved person to approach the appellate authority against a phodi, as applied by the Court.

Relying on M.R.R. Setty (Dead) by LRs. v. Government of Karnataka, the Court held that revisional or related authority cannot be exercised beyond the statutory time limit and that action taken outside that limit is unsustainable.

The Court also relied on State of Kerala v. M.K. Jose for the principle that disputed questions of fact are to be adjudicated before a Civil Court.

The respondent’s reliance on K.D. Sharma v. Steel Authority of India Ltd. and Prestige Lights Ltd. v. State Bank of India—concerning suppression of material facts in writ proceedings—was not accepted on the facts of this case.

The original phodi had been conducted in 1971, while respondent No. 5 approached the authorities decades later; the Court therefore concluded that the challenge was beyond the three-year period identified under Section 56(3).

The alleged discrepancy concerned measurement and boundaries, which were disputed and could not properly be determined in the writ proceedings.

The Court held that any claim by respondent No. 5 concerning the land should be established before the Civil Court, and that the Regional Joint Director erred in allowing the revision.

It confirmed the Deputy Director’s order dated 24 January 2025 and directed the Tahsildar, Chikkamagaluru, to restore the mutation and RTC entries as they stood before the revisional order.