Revenue authorities must defer mutation proceedings until civil courts resolve disputed title.

The petitioners challenged the Chhattisgarh Board of Revenue’s order dated 25 May 2023, which set aside orders of the Tehsildar and Commissioner but maintained the Sub-Divisional Officer’s order allowing mutation based on a registered sale deed dated 4 February 1975

The parties asserted competing claims to the land under separate registered sale deeds.

The petitioners and private respondents 6 to 10 had filed separate civil suits seeking declaration of title and permanent injunction concerning the disputed land; those suits were at the evidence stage

Whether the revenue authorities should proceed with mutation while competing claims of title to the land were pending before the civil court

Whether the Board of Revenue’s order should be set aside or the parties should instead pursue their title claims in the pending civil suits

The Court applied the principle that revenue proceedings are not a substitute for adjudication of disputed questions of title, which fall to be determined by the competent civil court

It further directed that revenue authorities await the civil court’s decision and thereafter conduct mutation proceedings in accordance with that adjudication and applicable law

The judgment cited no specific statute or precedent.

The competing registered sale deeds raised a substantial dispute over title, and the parties had already placed that dispute before the competent civil court in separate suits

Because title could not be determined through mutation proceedings, the Court considered it appropriate to leave the rival claims to the civil court and prevent further mutation proceedings until those claims were adjudicated

It expressly made no finding on the merits of either party’s title claim.

The revenue authorities were directed not to proceed with mutation concerning the disputed land until the civil court adjudicated title; thereafter, they must act in accordance with the judgment and decree and applicable law

No opinion was expressed on the merits of the rival title claims, and there was no order as to costs