Revenue Authorities lack jurisdiction to decide title or ownership disputes regarding immovable properties.

The petitioner filed a writ petition seeking to quash an order dated 11.10.2021 passed by the Commissioner for Land Administration (5th Respondent).

The petitioner sought a direction to restore S.F. No. 16, Molasi Village, as "Kuttai Poramboke" (water body poramboke), alleging that 10 individuals were encroachers.

Initially, the District Revenue Officer (12.09.2016) and the Revenue Divisional Officer (08.09.2017) determined that the subject land was private patta land, not government land.

The petitioner preferred a revision before the 5th Respondent after a delay of approximately 4.5 years, which was dismissed on the grounds of delay and laches.

1. Whether the Commissioner for Land Administration was justified in rejecting the revision petition on the grounds of delay and laches.

2. Whether the Revenue Authorities have the jurisdiction to adjudicate matters regarding title and ownership of immovable property.

The court applied the principle that Revenue Authorities are incompetent to decide matters of title, ownership, or complex civil rights in respect of immovable property.

Furthermore, the court upheld the administrative rule regarding the limitation period for filing revision petitions, noting that such petitions should typically be filed within 60 days.

The Court observed that the petitioner approached the 5th Respondent with a massive delay of 4.5 years, far exceeding the prescribed 60-day limit for revisions.

On the merits of the underlying land dispute, the Court noted that both the District Revenue Officer and the Revenue Divisional Officer had concurrently found, upon verification of revenue records, that the land in question was not a water body/government land but private patta land.

The Court reasoned that since the dispute essentially involves a challenge to ownership and the nature of the land (private vs. public), it falls outside the judicial scope of Revenue Authorities and must be determined by a civil forum.

The Court held that Revenue Authorities cannot decide title and granted the petitioner liberty to approach a competent Civil Court to establish any existing rights.

No costs were awarded.