Revenue authorities cannot reimpose restrictive conditions through internal circulars once prior judicial adjudication has attained finality.

In 1967, the petitioners' predecessor was granted a certificate under Section 63 of the Gujarat Tenancy and Agricultural Lands Act, 1948, allowing him to hold agricultural land despite being a non-agriculturist.

In 1973, via an internal communication, the Collector directed revenue authorities to enter restrictions—including a bar on sales without prior permission—into the mutation entries (Entry No. 237).

In 1975, the Deputy Collector set aside the restrictions, holding they were imposed without due process or statutory authority, and this order became final, leading to Entry No. 269 to delete the restrictions.

Decades later, during mutation proceedings for a registered Will (Entry No. 504), the Deputy Collector and later the Collector and Secretary (Appeals) re-imposed the 1973 restrictions prospectively.

1. Whether the revenue authorities could re-imposition land transfer restrictions based on an internal communication dated 11.01.1973 after those same restrictions had been set aside by a final order in 1975.

2. Whether the Deputy Collector exceeded his jurisdiction in RTS proceedings by overturning a previous final order of an authority of the same rank.

Section 63 of the Gujarat Tenancy and Agricultural Lands Act, 1948, and Rule 36(1)(f) of the associated Rules, which permit non-agriculturists to acquire land for agricultural purposes without necessarily imposing permanent bars on alienation.

The principle of finality of administrative orders; once a mutation entry imposing restrictions is quashed by a competent authority and that order attains finality, it cannot be revived through subsequent collateral proceedings.

Internal administrative communications do not carry the force of law unless translated into formal statutory orders following due process.

The original 1967 certificate was "general" and did not contain specific survey numbers or restrictive covenants; the 1975 order by the Deputy Collector had already adjudicated that the 1973 internal letter was insufficient to impose restrictions on old tenure land.

The respondent authorities committed a jurisdictional error because an officer of the same rank (Deputy Collector) cannot "upturn" or ignore a final order passed by a predecessor in 1975.

Earlier Section 84C proceedings regarding these lands had been dropped, further confirming the absence of valid statutory restrictions at the time of purchase.

The re-imposition of conditions during a simple mutation entry for a Will was an arbitrary exercise of power that ignored decades of settled legal status.

The High Court allowed the Special Civil Application and quashed the orders dated 29.09.2006, 08.04.2008, and 03.12.2024 to the extent that they imposed restrictions on the subject land, directing the mutation entry based on the Will be maintained without unauthorized restrictive conditions.