Erroneous records-of-rights entries require correction proceedings, not land conversion under Section 4C.

The subject plot was initially recorded as “Bagan” in the Revisional Settlement records but was subsequently recorded as “Khelar Math” in the Lower Revision records of rights.

The petitioners applied to the Block Land and Land Reforms Officer (BL&LRO) for correction of the entry. By order dated 13 September 2012, the BL&LRO rejected the application, holding that correction could not be made without a conversion proceeding.

The Appellate Authority affirmed that order.

The petitioners then approached the West Bengal Land Reforms and Tenancy Tribunal. The Tribunal quashed the orders of the BL&LRO and the Appellate Authority but granted liberty to the petitioners to apply under Section 4C of the West Bengal Land Reforms Act, 1955.

Challenging that direction, the petitioners contended that they sought correction of an erroneous entry, and not conversion or change in the character of the land.

Whether the petitioners’ application was one for correction of an erroneous entry in the records of rights, or one requiring a conversion proceeding under Section 4C of the West Bengal Land Reforms Act, 1955?

Whether the alteration of the land-use entry from “Bagan” to “Khelar Math” could be sustained in the absence of notice, hearing, and recorded reasons as contemplated by Section 51B of the 1955 Act?

Whether the matter ought to be remanded to the BL&LRO for fresh adjudication of the petitioners’ application for correction of the records of rights?

The Court applied Section 51B of the West Bengal Land Reforms Act, 1955, which authorises a specially empowered Revenue Officer, during the preparation or revision of records of rights and before their final publication, to revise or correct an entry either suo motu or on application, but only after giving interested persons an opportunity of hearing and recording reasons.

The Court also considered Section 4C of the 1955 Act, which applies where a raiyat seeks a change in the area or character of land, or conversion of land to a purpose different from that for which it was settled.

The governing principle was that a correction of records of rights cannot be treated as a conversion proceeding where the applicant merely seeks restoration of the previously recorded land-use or nature of the land.

The Court found that the BL&LRO had rejected the petitioners’ application on an erroneous premise, since the petitioners did not seek to convert the land or alter its character; they alleged that the LR entry itself had been incorrectly changed from “Bagan” to “Khelar Math”.

The alteration of the entry appeared to attract Section 51B because such correction or revision required notice and an opportunity of hearing to interested persons, together with recorded reasons.

The record contained no material showing that the petitioners had been heard or that any reasoned order had been passed for changing the entry.

Since Section 4C concerns an application by a raiyat seeking conversion or a change in the character or use of land, it was inapplicable to the petitioners’ request for correction and restoration of the earlier entry.

The Tribunal therefore erred in directing the petitioners to proceed under Section 4C, although it correctly set aside the earlier administrative orders.

The Calcutta High Court set aside the Tribunal’s judgment dated 4 September 2025, the BL&LRO’s order dated 13 September 2012, and the order of the Appellate Authority affirming it.

The BL&LRO, Singur, was directed to reconsider the petitioners’ application for correction of the records of rights on merits, after granting adequate hearing to all interested persons, including the petitioners and the State, and to pass a reasoned order preferably within six weeks from communication of the judgment.

No order was made as to costs.