Pending mutation proceedings must be concluded expeditiously after hearing all concerned parties.

The petitioner, Ravishankar, applied on 7 September 2021 for mutation of his name in the subject land on the basis of a registered sale deed dated 18 January 1993 executed by Hemlal, the recorded owner.

Respondent No. 1 objected to the mutation. The Tehsildar rejected the objection by order dated 12 November 2021. In revision under Section 50 of the Chhattisgarh Land Revenue Code, 1959, the Additional Collector set aside the Tehsildar’s order on 7 March 2022.

The Commissioner, Bilaspur Division, allowed the petitioner’s revision, set aside the Additional Collector’s order, and affirmed the Tehsildar’s order on 24 March 2023. Respondent No. 1 thereafter approached the Chhattisgarh Board of Revenue, which allowed her revision on 24 November 2025 and restored the Additional Collector’s order.

The petitioner challenged the Board’s order before the High Court, submitting that the original mutation proceedings were still pending before the Tehsildar and should be concluded.

1. Whether, in view of the pendency of the original mutation proceedings before the Tehsildar, the High Court should direct the Tehsildar to conclude those proceedings in accordance with law.

2. Whether the High Court should interfere with the impugned order dated 24 November 2025 passed by the Board of Revenue.

The Court proceeded on the principle that mutation proceedings are revenue proceedings and must be decided by the competent revenue authority in accordance with law, on the merits, and after providing all concerned parties a fair opportunity of hearing.

The proceedings before the Additional Collector, Commissioner, and Board of Revenue were treated as revisions under Section 50 of the Chhattisgarh Land Revenue Code, 1959.

The Court did not finally adjudicate the parties’ competing claims arising from the registered sale deed or determine title to the property.

The Court noted the sequence of orders passed by the Tehsildar, Additional Collector, Commissioner, and Board of Revenue, but found that the underlying mutation proceedings initiated on the petitioner’s application remained pending before the Tehsildar.

Since the mutation application had not yet been finally decided in the original proceedings, the Court considered it appropriate to require the competent authority to proceed with and conclude those proceedings rather than determine the substantive mutation claim itself.

The Tehsildar was directed to decide the matter expeditiously, in accordance with law and on its own merits, after granting due opportunity of hearing to all concerned parties.

The Tehsildar, Bamhnidih, was directed to proceed with Revenue Case No. 202109062400013/A-6/2020-21 and conclude it as expeditiously as possible, in accordance with law, on merits, and after hearing all concerned parties.