Revenue authorities cannot disregard a final civil court decree declaring a marriage void.

After the death of Chandkumar Jain, the petitioner sought mutation of agricultural land in her name on the basis of a will dated 1 June 2017.

The Tehsildar allowed the application; the Sub-Divisional Officer dismissed respondent no. 1’s appeal and affirmed the mutation order. In second appeal, the Additional Commissioner set aside the SDO’s order, holding that it had been passed contrary to natural justice and recording that respondent no. 1 was Chandkumar Jain’s legally wedded wife.

The petitioner challenged the Commissioner’s order, relying on a 7 November 1987 Family Court decree under Section 12(1) of the Hindu Marriage Act declaring the marriage between Chandkumar Jain and respondent no. 1 void. The decree had not been challenged.

1. Whether the Additional Commissioner could find that respondent no. 1 was Chandkumar Jain’s legally wedded wife despite the subsisting Family Court decree declaring their marriage void.

2. Whether respondent no. 1 could raise an objection in the mutation proceedings in light of that decree.

Section 12(1) of the Hindu Marriage Act was the basis of the Family Court decree declaring the marriage void.

The Court applied the principle that a judgment of a competent civil court is binding on revenue authorities; those authorities cannot disregard the civil court’s determination.

The mutation proceedings arose under Sections 109 and 110 of the Madhya Pradesh Land Revenue Code, 1959, with appeals under Section 44 of that Code.

The Family Court decree declaring the marriage void had attained finality because respondent no. 1 had not challenged it, including after the decree came to her knowledge through the 2024 writ proceedings.

The Commissioner therefore could not make a contrary finding that respondent no. 1 was the deceased’s legally wedded wife; doing so exceeded the Commissioner’s jurisdiction and disregarded the binding civil court determination.

On that basis, the Court held that respondent no. 1 had no right to object in the mutation proceedings.

The judgment did not decide the substantive validity of the will or the broader question of revenue authorities’ jurisdiction to mutate property on its basis.