Revenue Authorities lack jurisdiction to adjudicate the legality or genuineness of an arbitral award in mutation proceedings.

The petitioner, daughter of Late Pradeep Rai, sought mutation of ancestral land based on a panchayati/arbitral award dated 28.07.2001 (later affirmed by an affidavit-based agreement in 2015) following the death of the patriarch, Harendra Rai

The Circle Officer allowed the mutation in Case No. 109/2016-17

Respondent No. 6 (widow of Alok Rai) and Respondent No. 7 (daughter of Harendra Rai) challenged the mutation, alleging the award was fraudulent, lacked their informed consent, and was signed by an even number of arbitrators in violation of the Arbitration and Conciliation Act, 1996

The DCLR (Appellate Authority) set aside the mutation, a decision upheld by the Additional Collector (Revisional Authority) and the Bihar Land Tribunal, all of which questioned the genuineness and legality of the arbitral award

1. Whether the Revenue Authorities (DCLR, Additional Collector, and Bihar Land Tribunal) have the jurisdiction to adjudicate upon the validity, genuineness, or legality of an arbitral award during mutation proceedings

2. Whether the lack of notice to respondents by the Circle Officer caused such prejudice as to render the initial mutation order void, considering the limited scope of revenue inquiries

The court applied Section 3(2) of the Bihar Land Mutation Act, 2011, which governs the statutory process for mutation

It relied on the principle that an arbitral award can only be challenged before a competent Civil Court under Section 34 of the Arbitration and Conciliation Act, 1996

The court further applied the "prejudice doctrine" regarding natural justice as articulated in State of Uttar Pradesh v. Sudhir Kumar Singh & Ors. (2021) 19 SCC 706, which holds that a breach of the audi alteram partem rule does not invalidate an order unless actual prejudice is demonstrated

It also followed Inderjit Singh Grewal v. State of Punjab (2011) 12 SCC 588, establishing that revenue authorities cannot decide the genuineness of legal documents

The High Court reasoned that Revenue Authorities possess a limited jurisdictional mandate focused on possession and the existence of title documents; they are not "Civil Courts" and cannot "travel into the question of genuineness of a document" such as an arbitral award

If a party claims an award is fraudulent or legally deficient (e.g., even number of panches), the remedy lies exclusively under Section 34 of the 1996 Act

Regarding the violation of natural justice (non-service of notice), the court found that the respondents failed to show any "prejudice" beyond challenging the award's legality—an issue the Revenue Authority could not have resolved anyway

Therefore, the Tribunal and Revisional authorities erred by acting as a civil court to test the "peculiarity" or "suspicious" nature of the award

The High Court set aside the orders of the Bihar Land Tribunal (dated 15.02.2021), the Additional Collector (dated 31.10.2018), and the DCLR (dated 28.02.2017). The writ petition was allowed, effectively restoring the Circle Officer's order of mutation in favor of the petitioner