Failure to hear an affected stakeholder in mutation revision proceedings violates principles of natural justice and necessitates fresh adjudication.

The Petitioner, a real estate company, acquired 64 decimals of land in Mauza Babkarpur, Patna, through three registered sale deeds in 2008

Mutation was subsequently granted, and Jamabandi No. 1078 was created in its favor

Respondent No. 7, claiming prior purchase in 1996, initiated Jamabandi cancellation proceedings and a Title Suit (No. 04/2018), which was later withdrawn

Following a remittance from the Collector, the Circle Officer passed conflicting mutation orders favoring both parties at different times. Petitioner filed Mutation Revision No. 101/2024-25 against an adverse appellate order

Simultaneously, Respondent No. 7 filed Mutation Revision No. 25/2025-26. The Revisional Authority (ADM, Patna) passed an ex parte order on 14.10.2025, allowing Respondent No. 7’s revision and restoring its Jamabandi without noticing the Petitioner, despite the Petitioner’s cross-revision being pending before the same officer

1. Whether the Revisional Authority was duty-bound to hear the Petitioner before passing orders affecting the Jamabandi of the subject land

2. Whether the failure to tag and hear the Petitioner’s pending Revision Case alongside Respondent No. 7’s Revision Case amounted to a violation of the principles of natural justice

The Court applied the fundamental principle of Audi Alteram Partem (natural justice), holding that even administrative or quasi-judicial orders involving civil consequences—defined as deprivation of property rights, material loss, or non-pecuniary damages—must be consistent with the rules of natural justice

This principle ensures the prevention of miscarriage of justice to any party affected by a state order.

The Court observed that both the Petitioner and Respondent No. 7 had been engaged in a legal dispute over the same land for a decade, a fact recorded in previous orders

The ADM (Revisional Authority) was aware of the Petitioner's stake, as the Petitioner's own revision (No. 101/2024-25) was pending in the same court and the respondent's petition contained direct allegations against the Petitioner

The Court found that the ADM acted in "haste" and "mechanically" by ignoring the Petitioner's pending case and failing to issue notice

It reasoned that since the order resulted in the cancellation of the Petitioner's name from revenue records and restoration of the Respondent’s Jamabandi, it entailed "civil consequences" requiring a prior hearing

The Court quashed the order dated 14.10.2025 passed in Mutation Revision (MR) No. 25 of 2025-26. It revived and remitted the matter back to the Additional Collector, Patna (Respondent No. 4), with directions to tag both Revision Cases (No. 25/2025-26 and No. 101/2024-25) and pass a reasoned, comprehensive order after hearing all stakeholders. The parties were directed to maintain status quo until the fresh disposal