Once the pending SLP was dismissed, no basis remained to challenge continued mutation proceedings.

The dispute concerned diverted land bearing Khasra Nos. 448/31 and 448/32, admeasuring approximately 5,400 sq. ft., situated at Village Ameri, Tahsil Sakri, District Bilaspur.

Smt. Rashmi Sao had obtained an ex parte decree for declaration of title and permanent injunction in Civil Suit No. 109-A/2009 on 14 February 2017.

The petitioner’s applications under Order IX Rule 13 and Order IX Rule 9 CPC, appeal, W.P.(227) No. 1197/2024, and ultimately SLP (C) No. 11135/2025 were unsuccessful; the Supreme Court dismissed the SLP on 28 April 2026.

During the pendency of the SLP, the petitioner informed the revenue authorities and a banning remark was recorded against transfer of the land.

Nevertheless, Smt. Rashmi Sao executed a registered sale deed dated 7 April 2025 in favour of Respondent Nos. 4 to 6.

The Additional Tahsildar initially refused mutation on 2 May 2025, but subsequently registered a mutation case under Sections 109 and 110 of the Chhattisgarh Land Revenue Code on 12 June 2025.

The Additional Tahsildar stayed the revenue proceedings on 8 August 2025 until disposal of the SLP.

Notices and an Ishtehar were thereafter issued on 22 August 2025, allegedly despite the stay.

The stay was vacated on 10 September 2025.

The petitioner challenged the orders dated 12 June 2025 and 10 September 2025, alleging lack of jurisdiction under Section 51(1)(i) of the Chhattisgarh Land Revenue Code and violation of natural justice.

Whether the Additional Tahsildar could validly register and continue mutation proceedings after earlier refusing mutation in view of the pending proceedings before the Supreme Court, without obtaining written sanction under Section 51(1)(i) of the Chhattisgarh Land Revenue Code?

Whether the order dated 10 September 2025 vacating the stay was liable to be quashed for having been passed without affording the petitioner an effective opportunity of hearing, in violation of natural justice?

Whether the petitioner’s challenge survived after the Supreme Court dismissed SLP (C) No. 11135/2025 on 28 April 2026?

The Court considered the mutation jurisdiction exercised under Sections 109 and 110 of the Chhattisgarh Land Revenue Code, which govern reporting and recording of transfers or acquisitions of rights in land.

The petitioner relied on Section 51(1)(i) of the Code, contending that, after the earlier refusal of mutation, the Additional Tahsildar could not entertain a fresh mutation application without written sanction from the immediately superior authority.

The Court also considered the principles of natural justice, particularly the requirement of an effective opportunity of hearing before an order adversely affecting a party is passed.

In exercising writ jurisdiction, the Court applied the principle that interference was unwarranted where the principal factual foundation of the challenge had ceased to exist and no sufficient ground for extraordinary relief remained.

The Court held that the petitioner’s principal objection was founded on the pendency of SLP (C) No. 11135/2025 and the consequent justification for keeping the mutation proceedings in abeyance.

Since the Supreme Court had dismissed the SLP on 28 April 2026, the circumstance underlying the petitioner’s challenge no longer survived.

The Court noted that the petitioner had failed to obtain relief against the original ex parte decree and had remained unsuccessful before the trial court, appellate court, High Court, and Supreme Court.

Although the petitioner alleged statutory non-compliance and denial of hearing, the Court found no sufficient ground to exercise writ jurisdiction against either the registration of the mutation case or the subsequent vacation of stay.

The revenue authority was, however, directed to proceed with the mutation case strictly in accordance with law and independently of the observations made in the writ proceedings.

It declined to quash the order dated 12 June 2025 registering the mutation proceedings or the order dated 10 September 2025 vacating the stay, principally because the Supreme Court had meanwhile dismissed the SLP on which the petitioner’s objection was based.

The writ petition was accordingly dismissed.

The revenue authorities were directed to proceed with the mutation proceedings in accordance with law, without being influenced by the observations in the judgment and subject to the parties’ available legal rights and remedies.