Revenue authorities must mutate entries based on registered deeds without adjudicating title or transaction validity.

The petitioners purchased agricultural land (Survey No. 433, Village Vadald, Anand) from Dahiben, the recorded Administrator and disciple of Yogendraprasad Guru, via a registered sale deed dated 14.03.2007

Following the sale, Revenue Entry No. 11023 was mutated. However, the Respondent No. 3 (Mamlatdar) cancelled the entry on 14.03.2012, asserting that the land fell under the Gujarat Devasthan Inams Abolition Act, 1969, and the Administrator lacked authority to sell "Devsthan" property

This cancellation was upheld through successive appeals and revisions by the Assistant Collector, the Collector, and finally the Special Secretary Revenue Department (SSRD) on 16.02.2016

The petitioners argued that Dahiben had been the recorded occupant since 1973 (Entry No. 4864) and that revenue authorities are legally bound to mutate entries based on registered documents

1. Whether the revenue authorities exceeded their jurisdiction by cancelling a mutation entry based on a registered sale deed by adjudicating the validity of the transaction under the Devasthan Inams Abolition Act?

2. Whether the revenue authorities are under a statutory obligation to give effect to a registered sale deed in the record of rights under the Bombay Land Revenue Code?

The court primarily applied Section 135-C of the Bombay Land Revenue Code, which mandates that revenue authorities must mutate entries upon the production of a registered sale deed

It relied on the principle established in Evergreen Apartment Cooperative Housing Society v. Special Secretary, Revenue Department (1991) and Siddharth B. Shah v. State of Gujarat (1999), holding that RTS (Record of Rights) proceedings are for fiscal purposes only and do not create or determine title

Furthermore, the court applied the doctrine from Gandabhai Dalpatbhai Patel v. State of Gujarat (2005), stating that revenue authorities cannot decide the validity of a transaction or title based on other enactments; such disputes must be relegated to a competent Civil Court

The court found that Dahiben’s status as Administrator was legally recorded in 1973 (Entry No. 4864), granting her the apparent right to execute the deed

The court reasoned that when a transaction is evidenced by a registered document, the revenue authority’s role is ministerial rather than adjudicatory; they must take cognizance of the deed for mutation purposes unless it is annulled by a Civil Court

The court criticized the revenue authorities for assuming the power to declare the sale "invalid" under the Devasthan Inams Abolition Act, noting that such a determination of "breach of condition" or "legality of title" falls outside the limited scope of RTS proceedings under Rule 108 of the Bombay Land Revenue Rules

Since no civil litigation had challenged the sale deed, the revenue authorities were not justified in ignoring the registered instrument

The court held that the revenue authorities are duty-bound to give effect to registered sale deeds at the first instance under Section 135-C of the Revenue Code

The concerned authority was directed to restore and mutate Entry No. 11023 in the revenue records within four weeks based on the registered sale deed