Revisional powers must be exercised within reasonable time and cannot adjudicate civil rights or statutory breaches.

Originally owned by Raghunathbhai Lalabhai, the land was mutated in the names of his widow, Bai Suri, and his two sons (the petitioners) via Entry No. 1208 in 1975.

Before her death in 1989, Bai Suri executed a registered Will in 1988 bequeathing the property to Respondent Nos. 1 and 2.

Based on this Will, Entry No. 1641 was mutated in 1993 with the "consent" statements of the petitioners and subsequently certified.

In 2012, after a lapse of 19 years, the Collector of Vadodara initiated suo motu revision proceedings under Rule 108(6) of the Gujarat Land Revenue Rules, 1972.

The Collector cancelled the 1993 entry, holding that the property was ancestral, the Will was executed without absolute ownership, and the land was of restricted tenure.

The Special Secretary Revenue Department (SSRD) reversed the Collector’s order in 2014, citing inordinate delay and jurisdictional errors.

The petitioners challenged the SSRD's order before the High Court.

1. Whether the Collector’s exercise of suo motu revisional power after an inordinate delay of 19 years was legally valid.

2. Whether a revenue authority, while adjudicating mutation entries (RTS proceedings), has the jurisdiction to determine the validity of a registered Will or adjudicate civil rights.

3. Whether the revenue authority can cancel an entry by cross-utilizing powers under different statutes (e.g., alleging breach of tenure while deciding a mutation dispute).

The court primarily applied Rule 108(6) of the Gujarat Land Revenue Rules, 1972, regarding the revision of mutation entries.

State of Gujarat v. Patel Raghav Natha & Ors. (1969), which established that suo motu revisional powers must be exercised within a "reasonable time," typically not exceeding three years.

Evergreen Apartment Co-op. Housing Society v. Special Secretary, Revenue Department (1991), holding that revenue authorities in RTS proceedings cannot adjudicate title or transactions' validity under other special enactments; they must follow registered title documents unless set aside by a competent Civil Court.

The Court found that the Collector's intervention after 19 years was an unsustainable exercise of power due to the lack of a reasonable timeframe, as mandated by the Patel Raghav Natha doctrine.

The Court reasoned that mutation entries are for fiscal purposes only and do not determine title. Since the petitioners had withdrawn their civil suit challenging the Will, the registered document remained valid and the revenue authorities lacked the jurisdiction to declare it void or decide if the property was "ancestral" versus "self-acquired".

Furthermore, the Court criticized the Collector for "cross-utilizing" powers by canceling the entry based on alleged breaches of land tenure (new/impartible tenure).

Following the Evergreen Apartment rule, the Court held that if a statutory breach is suspected, independent proceedings under that specific law must be initiated rather than summarily canceling a revenue entry under Rule 108.

Finally, the Court noted that the petitioners had originally consented to the entry in 1993, making their subsequent challenge inequitable.

The High Court dismissed the petition, confirming the SSRD’s order dated 23.05.2014, and discharged the rule. All interim reliefs were vacated.