Revenue authorities cannot unsettle decades-old land grants through unjustifiably belated action.

The petitioner challenged a Tahsildar’s order dated 1 June 2021 concerning land at Kalmane Village, Survey No. 49.

He relied on grant orders for 2 acres in favour of his father and 3 acres in favour of his mother, and RTC extracts said to record coffee cultivation on the land.

He also relied on an earlier High Court order directing the authorities to conduct phodi and durasth work.

The State supported the Tahsildar’s finding that the land had not been cultivated for a considerable period.

The petitioner sought, among other relief, proceedings against the sixth respondent under Section 192-A of the Karnataka Land Revenue Act, 1964.

Where legislation prescribes no limitation period for exercising a revisional or corrective power, the authority must nevertheless act within a reasonable time; what is reasonable depends on the statute, the rights affected, and the circumstances.

The Court relied on the principles stated in Joint Collector, Ranga Reddy District v. D. Narsing Rao, Ibrahimpatnam Taluk Vyavasaya Coolie Sangham v. K. Suresh Reddy, State of H.P. v. Rajkumar Brijender Singh, and State of Punjab v. Bhatinda Milk Producers Union Ltd.: an unexplained, belated exercise of power may be impermissible even where fraud is alleged, particularly where long-standing rights or entries would be disturbed.

The Court also referred to Shyamo Devi v. State of U.P., which reiterated that statutory power without a specified limitation period must still be exercised within a reasonable period.

The Court noted that the grants to the petitioner’s parents were undisputed and that the RTC extracts recorded coffee cultivation on the subject land.

It also considered the earlier direction to conduct phodi and durasth, which had not been carried out on the stated ground that the land was not under cultivation.

Applying the reasonable-time principle, the Court held that action interfering with grants made decades earlier was belated and unsupported by adequate justification.

It further found the Tahsildar’s finding of no plantation arbitrary in view of the RTC extracts.

The Court declined to grant the separate prayer for proceedings under Section 192-A.

The Tahsildar was directed to enter the petitioner’s name in the revenue records and complete phodi and durasth of the subject land, with the assistance of the jurisdictional Assistant Director of Land Records, within six months of receiving the certified copy of the order.

The Court made no order on the prayer to initiate proceedings against the sixth respondent under Section 192-A.