Revisional authority under Madhya Pradesh Land Revenue Code cannot direct trust dissolution under Public Trusts Act.

The petitioner, a registered public trust, filed an application under Section 115 of the Madhya Pradesh Land Revenue Code (MPLRC) seeking a correction of revenue entries to substitute the temple's name with the Trust's name

The Sub-Divisional Officer rejected the application on December 14, 2021, on the grounds that the temple is a government-controlled (Shasan Adheen) entity

On June 22, 2026, the Collector (Revisional Authority) affirmed the rejection and further directed the initiation of proceedings under Section 26 of the M.P. Public Trusts Act, 1951, for the dissolution of the Trust

The petitioner challenged these orders before the High Court, asserting that the Collector exceeded his revisional jurisdiction and violated principles of natural justice

1. Whether the Collector, while exercising revisional jurisdiction under the MPLRC, had the authority to direct the dissolution of a public trust under Section 26 of the M.P. Public Trusts Act, 1951

2. Whether the refusal to correct the revenue entries was legally sustainable

Section 50 of the Madhya Pradesh Land Revenue Code, 1959, which governs the scope of revisional jurisdiction regarding revenue entries

Section 26 of the Madhya Pradesh Public Trusts Act, 1951, which mandates that only the Registrar—after being satisfied of mismanagement or failure of trust objects and after affording a hearing to the working trustee—may seek directions from a competent court

The Court observed that the Collector was exercising limited revisional jurisdiction under Section 50 of the MPLRC to examine the correctness of revenue entries.

The Court found that directing the dissolution of a trust under Section 26 of the Public Trusts Act was de-hors the statutory scheme of that Act, as such powers are specifically vested in the Registrar and require a predefined procedure including a hearing for the trustee.

The Court held that the Collector’s mandate for dissolution in paragraph 7 of the impugned order was procedural and jurisdictional error.

Regarding the refusal to correct the revenue entries (the primary dispute), the Court found no illegality in the findings that the temple was government-managed.

It set aside the direction contained in paragraph 7 of the Collector’s order dated June 22, 2026, regarding the initiation of dissolution proceedings under Section 26 of the M.P. Public Trusts Act. The remaining portion of the order, affirming the rejection of the revenue entry correction, was sustained.

The Court clarified that the Registrar remains free to initiate proceedings under the Public Trusts Act if done in accordance with the prescribed legal procedure.