Revenue authorities must mutate entries based on registered sale deeds regardless of alleged statutory violations or title disputes.

Petitioner No. 1 purchased land (Old Survey No. 137, New Survey No. 2) in Village Lear via a registered sale deed in 1982

Mutation Entry No. 693 was certified in 2004

Petitioner No. 1 then sold the land to Petitioner No. 2 via a registered deed in 2007, resulting in certified Entry No. 784

Respondents 6 and 7 challenged these entries before the Deputy Collector in 2013—after a 31-year delay—claiming the land originally belonged to their forefathers and was illegally mortgaged

The Deputy Collector dismissed the appeal

On revision, the Collector also dismissed the appeal but concurrently issued suo motu directions to the Mamlatdar to conduct an inquiry and cancel all mutation entries made after the 1970 promulgation

The Special Secretary, Revenue Department (Appeals) [SSRD] confirmed this order

Whether the Collector exceeded his jurisdiction under RTS (Record of Rights) proceedings by issuing directions for inquiry and cancellation of entries in the absence of a specific prayer and beyond the scope of the appeal

Whether revenue authorities are legally obligated to mutate entries based on registered sale deeds under Section 135-C of the Bombay Land Revenue Code

Whether the challenge to the revenue entries was barred by inordinate delay and laches

Section 135-C of the Bombay Land Revenue Code, which mandates that the revenue authority must record and certify entries based on registered documents

The principle that revenue entries have fiscal value and do not determine title—a principle affirmed in Evergreen Apartment Co-operative Housing Society Ltd. v. SSRD [1991 (1) GLR 113] and Nathubhai Meraman Darji

The doctrine from State of Gujarat v. Patel Raghav Natha [AIR 1969 SC 1297], which holds that revenue authorities cannot adjudicate complex questions of title in RTS proceedings

The Court reasoned that once a registered sale deed is executed, Section 135-C imposes a statutory duty on the revenue department to update the Record of Rights; the validity of such a deed can only be challenged in a competent Civil Court, not before revenue authorities

The Court found the Collector’s directions "dehors the statutory provisions" because he traveled beyond the scope of the specific litigation between the parties to order a sweeping inquiry into all entries since 1970 without a prayer from the litigants

The Court emphasized that Petitioner No. 1’s 1982 deed remains valid and uncancelled by any court; thus, the revenue office was bound to give it effect

Additionally, the 31-year delay in challenging the entries was deemed "gross and inordinate," further invalidating the intrusive directions issued by the lower authorities

The Court allowed the petitions and quashed the orders of the SSRD and the Collector insofar as they issued directions for inquiry and cancellation

The Court directed the restoration of Revenue Entry Nos. 693 and 784 in favor of the petitioners

Rule made absolute