Revenue records alone do not establish title or entitlement to land acquisition compensation.

The appellant, the Deputy Chief Engineer, N.F. Railway, challenged the judgment and award dated 6 September 2023 passed by the Land Acquisition Judge, South Tripura, Sabroom, in CM (L.A.) No. 77 of 2022, by which the compensation payable in respect of the acquired land was enhanced.

The appellant contended that the Land Acquisition Judge had not framed an issue regarding the claimants’ ownership or entitlement to receive compensation.

According to the appellant, the claimants had produced no title deed or other document establishing ownership and had relied only on khatians/revenue records, which could not by themselves prove title.

The respondents submitted that they had produced khatians and sought an opportunity to place further documents supporting their claim before the Land Acquisition Judge.

Whether the Land Acquisition Judge erred in enhancing compensation without framing and deciding an issue regarding the claimants’ ownership and entitlement to receive compensation.

Whether khatians or other revenue records, without supporting title documents or evidence, establish ownership of the acquired land.

Whether the matter should be remanded for determination of title and ownership after permitting both parties to adduce oral and documentary evidence.

The Court applied the principle that a person seeking compensation for compulsory acquisition must establish ownership or a legally recognised interest in the acquired land.

Revenue records, mutation entries, jamabandis and tax receipts are primarily fiscal documents; they do not constitute documents of title, confer ownership, or create or extinguish title.

The Court relied on Vadiyala Prabhakar Rao v. Government of Andhra Pradesh, 2026 INSC 450, particularly paragraph 16, which holds that revenue entries serve a fiscal purpose, have no presumptive value regarding title, and cannot establish ownership against the Government.

The Court further applied the procedural principle that the entitlement to compensation must be adjudicated after framing the relevant issue and allowing the parties to produce appropriate evidence.

The High Court found that the compensation award had been enhanced without a specific determination of whether the claimants owned the acquired land or were otherwise entitled to receive compensation.

Since the claimants appeared to rely principally on khatians, and revenue records alone do not establish title under the rule stated in Vadiyala Prabhakar Rao, the Court held that ownership could not be presumed without supporting documentary and oral evidence.

The Court nevertheless recognised that a person who proves ownership and establishes loss of land through acquisition must be appropriately compensated.

Conversely, a person who fails to prove ownership cannot receive compensation from the public exchequer.

Accordingly, the Court considered a remand necessary so that the Land Acquisition Judge could frame the issue of title, permit both sides to adduce evidence, and determine the claimants’ entitlement in accordance with law.

The Land Acquisition Judge was directed to frame an issue concerning the claimants’ title and ownership, allow both parties to produce oral and documentary evidence, and thereafter decide their entitlement to compensation in accordance with law.

The appeal was consequently disposed of, and any pending applications were also disposed of.