Revenue records do not establish title; compensation requires proof of ownership.

The appellant challenged the judgment and award dated 05.06.2018 passed by the Land Acquisition Judge, South Tripura, Belonia, in LA (Ref.) No. 18 of 2016, by which the compensation payable to Respondent No. 1 was enhanced.

The appellant contended that the Land Acquisition Judge had neither framed an issue regarding the claimant’s ownership or entitlement to compensation nor required production of a title deed or other proof of ownership.

The claimant had relied principally on khatians, which, according to the appellant, could not establish title.

Respondent No. 1 submitted that he would produce relevant documents before the trial court and stated that a share of the compensation had already been released to him.

The High Court considered the record and the submissions of both parties.

Whether the Land Acquisition Judge erred in enhancing compensation without framing and deciding an issue concerning the claimant’s title, ownership, and entitlement to receive compensation.

Whether khatians or revenue records, in the absence of title deeds or other cogent evidence, are sufficient to establish ownership of the acquired land and entitlement to compensation.

Whether the judgment and award dated 05.06.2018 required to be set aside and the matter remanded for fresh adjudication after giving the parties an opportunity to adduce evidence.

The Court applied the principle that a person claiming compensation for acquired land must establish ownership or a legally recognizable entitlement to the compensation before receiving public funds.

Relying on Vadiyala Prabhakar Rao & Ors. v. Government of Andhra Pradesh, 2026 INSC 450, the Court held that revenue records, mutation entries, and tax receipts are maintained primarily for fiscal purposes; they are not documents of title, do not confer or extinguish ownership, and have no presumptive value on the question of title, although they may indicate possession.

The Court therefore required the Land Acquisition Judge to frame a specific issue regarding title and ownership and decide it after permitting both sides to adduce oral and documentary evidence.

The High Court found that the compensation enhancement had been granted without an adequate determination of whether Respondent No. 1 actually owned the acquired land or was otherwise entitled to compensation.

Since the claimant had relied on khatians and had not produced a title deed or other ownership documents, the Court held that the entitlement question could not be conclusively resolved on the existing record.

Applying the principle that revenue entries may indicate possession but cannot prove title, the Court directed a fresh adjudication focused on ownership and entitlement.

The Court also emphasized that while a genuine landowner deprived of land through acquisition must be compensated, an unproven claimant cannot receive money from the government exchequer merely on the basis of revenue entries.

The matter was remanded to the Land Acquisition Judge, South Tripura, Belonia, with directions to frame an issue regarding the claimant’s title and ownership, permit both parties to produce relevant evidence, and decide the claim for compensation afresh in accordance with law.

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