Revenue authorities must decide map-correction proceedings while leaving title disputes to civil courts.

The petitioner claimed rights over Survey No. 1597/2, measuring 0.658 hectare, and sought correction of the revenue map under Section 107(5) of the M.P. Land Revenue Code.

An order allowing correction, passed on 15 April 2021, was set aside on 22 April 2022, and the matter was remanded for a fresh decision after hearing all concerned parties.

Following further proceedings, the Sub-Divisional Officer (SDO), Dabra, passed the impugned order dated 12 July 2024.

The dispute also involved earlier batankan proceedings and pending civil litigation concerning the property.

The petitioner challenged the SDO’s order before the High Court.

1. Whether the SDO could bring the proceedings for correction of the revenue map and batankan to an end without deciding the Section 107(5) application afresh in accordance with the remand directions.

2. Whether the revenue authority, while deciding the map-correction and batankan proceedings, could determine questions of title, ownership, possession, or other substantive civil rights in the face of pending civil proceedings.

Section 107(5) of the M.P. Land Revenue Code provides the basis for an application seeking correction of a revenue map; such an application must be considered and decided by the competent revenue authority in accordance with law.

Where proceedings have been remanded for hearing interested parties and passing a fresh speaking and reasoned order, the authority must decide the matter within its revenue jurisdiction.

The authority must not adjudicate questions of title, ownership, possession, or other substantive civil rights reserved for the competent civil court.

The High Court noted that the Section 107(5) proceedings had been remanded for a fresh decision after hearing all concerned parties, and concluded that they could not properly be terminated without examination within the revenue authority’s limited jurisdiction.

At the same time, because civil proceedings concerning the property were pending, the SDO’s reconsideration had to be confined to revenue matters and remain subject to the outcome of those proceedings.

The Court expressed no view on the parties’ competing claims to the property.

The petition was disposed of without costs; no opinion was expressed on title, ownership, or possession.