Review jurisdiction cannot extend to lands or parties beyond the scope of the original revision proceedings.

The petitioners in these four writ petitions are Khatiandars (tenant-holders) or purchasers from Khatiandars of various plots under KP Patta No. 79 in Dhubri District.

In 2012, private respondents (Respondents 7-12) filed Misc. Case No. 06/2012-13 before the Settlement Officer seeking deletion of certain names from the records specifically for Dag No. 31.

The Assistant Settlement Officer allowed this deletion on 28.05.2012.

The petitioners in WP(C) 443/2025 challenged this via Revision Petition No. 99RA(DBR)/2018 before the Assam Board of Revenue, which passed an ex-parte order on 29.12.2018 setting aside the deletion and restoring the petitioners' names.

The private respondents then filed a Review Petition (Case No. 5RA(DBR)(RVW)/2022). On 07.01.2025, the Board not only recalled its earlier order but also directed the restoration of land records for seven additional dags (27, 28, 29, 30, 31, 40 & 302) totaling 48 bighas—exceeding the scope of the original 2012 dispute which only concerned Dag No. 31.

1. Whether the Assam Board of Revenue exceeded its review jurisdiction by passing orders regarding dags that were not part of the original proceedings.

2. Whether the orders passed by the Board in 2018 and 2025 were in violation of the principles of natural justice and proper procedure.

Section 7 of the Assam Board of Revenue Act, 1962, which governs the Board's power to review its own orders.

Regulation 151 of the Assam Land and Revenue Regulation, 1886, concerning the supervisory and revisional jurisdiction of the Board over revenue proceedings.

Principle of Natural Justice, which mandates that no order affecting a party's rights should be passed without providing an opportunity for a hearing.

The High Court found that the Board’s 2018 ex-parte order was arbitrary as it was passed a day after filing without hearing the affected private respondents.

Regarding the 2025 review order, the Court held that while the Board was justified in recalling the flawed 2018 order, it committed a jurisdictional error by expanding the scope of relief. The original 2012 dispute was strictly limited to Dag No. 31 (approx. 24 bighas), yet the Board’s review order affected seven different dags (approx. 48 bighas).

The Court reasoned that review jurisdiction cannot be used to adjudicate on properties or parties (like the petitioners in WP(C) 683/2025 and 678/2025) that were never part of the primary litigation. Consequently, the Board acted beyond its authority by summarily altering records for lands not in issue.

The Court directed the Assam Board of Revenue to decide Revision Petition No. 99RA(DBR)/2018 afresh, limited strictly to Dag No. 31, after hearing all parties. The parties were ordered to appear before the Board on 15.05.2025, with private respondents free to initiate separate proceedings for the other dags.