Revenue entries affecting civil rights cannot be altered without notice, hearing, and a reasoned determination.

The petitioner claimed rights over Survey Nos. 410/1A, 410/1D and 382/1, measuring in total 6 acres and 17 cents.

He relied on assignment proceedings in favour of his vendors, registered sale deeds, Patta No. 282 and other revenue records.

He alleged that his name was removed from the patta and the lands reclassified as “Panchamar Tharisu” without notice or a hearing.

After earlier representations and proceedings before the High Court, the petitioner challenged the adverse revenue decision and sought restoration of the patta in W.P.(MD) No. 7830 of 2023.

In W.P.(MD) No. 7771 of 2023, he sought consideration of his representation for an agricultural electricity connection, which he said was affected by the disputed revenue entries.

Whether the petitioner’s request could be rejected merely by relying on the current “Panchamar Tharisu” classification without determining the nature and terms of the original assignments.

Whether the petitioner’s revenue entry could be deleted or altered to his prejudice without notice, an opportunity to be heard and a reasoned order.

What direction concerning the agricultural electricity connection was appropriate while the revenue dispute remained unresolved.

Under the principles of natural justice, revenue authorities must give notice and an opportunity of hearing before altering entries in a manner affecting an individual’s asserted rights, and must give reasons based on relevant records.

In S. Raja Lakshmi v. District Collector, Madurai District and others, W.P.(MD) No. 3387 of 2015, order dated 10 February 2020, the Court held that revenue entries could not be altered to an individual’s prejudice without notice and an opportunity to be heard; the decision also required the classification dispute to be assessed against the relevant assignment records.

The present order identifies no further specific statutory provision as the basis for its decision; the petitions were brought under Article 226 of the Constitution.

The Court held that the petitioner’s assignment proceedings, sale deeds and claimed prior patta required examination, but that the later “Panchamar Tharisu” entry also could not be disregarded without investigating its basis.

The authority therefore had to assess the original assignment files, conditions, historical and current revenue records, and mutation proceedings separately for each survey field, and identify the authority and process by which the petitioner’s name was removed.

The earlier order directing consideration of representations and the closure of contempt proceedings did not determine whether the adverse classification was legally correct.

As the petitioner’s representation was unclear about whether it included Survey No. 382/1, the authority was directed to seek clarification and consider that field if the claim was maintained.

The Court declined to determine title or grant an electricity connection; the electricity authority was instead required to identify the benefit sought and decide the application under the applicable rules and scheme conditions.

The exercise was to be completed within eight weeks.

W.P.(MD) No. 7771 of 2023 was disposed of with a direction that the competent electricity authority decide the petitioner’s application by a reasoned order within four weeks after receiving the revenue decision; no connection or scheme eligibility was granted in advance.

The Court expressed no final view on title, assignment validity, land classification or electricity eligibility.