Revenue authorities cannot delete mutations based on alleged forgery once a competent criminal court acquits the party.

The petitioner was granted a Patta (land allotment) for agricultural land (Survey No. 1654/Min/1, Village Mohana) on 11.01.1985.

After his name was deleted from revenue records without justification, he filed WP No. 4984/2007, resulting in an order dated 05.01.2009 by the Additional Tehsildar restoring his name.

However, on 16.03.2009, the same authority again deleted his name and initiated criminal proceedings alleging the Patta was forged.

In 2014, the Sessions Court acquitted the petitioner, finding the prosecution failed to prove forgery.

Despite this acquittal, the Sub-Divisional Officer (19.08.2020) and the Commissioner (21.10.2021) dismissed the petitioner’s appeals, affirming the deletion of his name.

The petitioner subsequently challenged these orders under Article 226/227.

The Court primarily applied the principles of natural justice and the procedural requirements for mutating/deleting revenue entries under the Madhya Pradesh Land Revenue Code, 1959.

The Court relied on the doctrine that once the foundation of an administrative action (in this case, the allegation of forgery) is negated by a competent judicial finding (the acquittal by the Sessions Court), the consequential administrative orders cannot be sustained.

The court emphasized the exercise of extraordinary jurisdiction under Articles 226 and 227 of the Constitution of India to correct arbitrary and illegal administrative actions.

The Court reasoned that the 16.03.2009 order was predicated entirely on the allegation that the petitioner's Patta was forged.

The judgment dated 24.07.2014 in Sessions Trial No. 51/2011 explicitly held that the prosecution failed to establish forgery, thereby removing the "very foundation" of the revenue department's case.

The Court found that the appellate authorities (SDO and Commissioner) committed a legal error by "mechanically" affirming the lower authority's orders without considering the legal impact of the acquittal.

The court noted the procedural lapse where the petitioner’s name was deleted without a show-cause notice or an opportunity to be heard, rendering the proceedings void ab initio.

The Court held that because the allegation of forgery did not survive the criminal court's scrutiny, the revenue entries must reflect the petitioner's title.

The Court restored the order dated 05.01.2009 and directed the respondents to restore the petitioner's name in the revenue records and carry out consequential entries within eight weeks.