Revenue authorities cannot reopen land-restoration proceedings already affirmed by final judicial orders.

The petitioners claimed through Dala Bylappa, who acquired 31 acres 27 guntas in Sy. No. 62, Madappanahalli Village, at a public auction in 1927; after his death, the land was transferred to his son Narasimhaiah.

In 2004, Narasimhaiah sought restoration of the land from Phada. The Deputy Commissioner ordered restoration on 30 June 2012, but later purported to review that order and directed that the Government’s name be entered in the revenue records.

The review order was quashed in earlier writ proceedings; following remand by the Supreme Court, the High Court again quashed it, and the State’s appeal was dismissed. In contempt proceedings, the authorities undertook to restore the revenue entries.

The Tahsildar subsequently filed Appeal No. 481/2024 before the Karnataka Appellate Tribunal challenging the 22 September 2012 order, while the petitioners in the connected petition challenged proceedings in RRT (2)(NA) CR.190/2009-10.

1. Whether the Tahsildar’s appeal before the Karnataka Appellate Tribunal, brought after prior proceedings had upheld restoration of the revenue entries, could continue.

2. Whether the proceedings in RRT (2)(NA) CR.190/2009-10 should be quashed in light of the earlier litigation and the asserted finality of the restoration proceedings.

Rule 119 of the Karnataka Land Revenue Rules, 1966 provides for restoration of a forfeited occupancy or alienated holding on payment of the arrears and related sums, subject to the Rule’s conditions.

Sections 127 and 136(3) of the Karnataka Land Revenue Act, 1964 were relevant to the recording of revenue entries and the proceedings concerning them.

The Court relied on the principle that a quasi-judicial authority has no inherent power to review its own order; such power must be conferred by statute. It referred to N. Chandareddy v. State of Karnataka, ILR 2016 KAR 3275, and the authorities cited there on the limits of review jurisdiction.

It also relied on Benedict Denis Kinny v. Tulip Brian Miranda and Prachi Prasad Parab v. State of Maharashtra, (2021) 12 SCC 780, concerning judicial intervention where authorities arbitrarily revive stale claims.

The Court found that the restoration order of 30 June 2012 had survived successive proceedings: the later review order was quashed, the State’s appeal was dismissed, and the authorities undertook to restore the entries.

In that context, the Tahsildar’s later appeal challenging the 22 September 2012 order was, in the Court’s view, an attempt to reopen a matter already concluded by the prior proceedings; it was also initiated after about 12 years without an acceptable explanation.

The Court rejected the State’s allegations concerning the petitioners’ documents as insufficient, at that stage, to justify reviving the proceedings after such delay.

It consequently held that the connected RRT proceedings also could not continue.

It quashed Appeal No. 481/2024 before the Karnataka Appellate Tribunal and directed the Tahsildar to implement the orders in W.A. No. 1289/2023 and C.C.C. No. 418/2023 within two weeks of receiving a certified copy of the judgment.

It also quashed the proceedings in RRT (2)(NA) CR.190/2009-10.