Section 115 of MPLRC is the efficacious remedy for correcting revenue records, barring writ jurisdiction.

The petitioner, a resident of Village Majhari, challenged the order dated 14.07.2025 passed by the Additional Collector, District Shivpuri, which dismissed his appeal regarding the correction of revenue records

The petitioner claimed that land originally allotted to his father (Survey No. 335, later renumbered as 578, 606, and 607) was wrongly recorded in the name of Respondent No. 4 due to a clerical error in the revenue map where Survey No. 605 and 606 were transposed

After the Sub-Divisional Officer (SDO) rejected his application twice—once following a remand by the Additional Collector—the petitioner filed this Writ Petition under Article 226 of the Constitution

1. Whether the impugned orders passed by the revenue authorities were unsustainable due to a failure to appreciate clerical errors and material evidence provided by the Revenue Inspector

2. Whether the High Court should exercise its writ jurisdiction under Article 226 when an alternative statutory remedy for the correction of land records is available

Section 115 of the M.P. Land Revenue Code, 1959, which establishes a specific statutory mechanism for the correction of wrong or incorrect entries in the khasra or other land records by superior officers

The court relied on the judicial principle that writ jurisdiction under Article 226 of the Constitution of India should not be exercised when an efficacious alternative remedy is available

the petitioner had incorrectly sought relief under Sections 89 and 105 of the same Code

The Court observed that the core of the dispute involved the correction of alleged wrong entries in revenue records following settlement and consolidation proceedings

The petitioner argued that the subordinate authorities ignored the Revenue Inspector’s report confirming the survey number renumbering and mapping errors

The Court found that the petitioner had pursued his claim under Sections 89 and 105 of the M.P. Land Revenue Code, which were not the appropriate provisions for the relief sought

By reading Section 115 of the Code, the Court determined that the legislature provided a clear and direct procedure for the Tahsildar to rectify such errors after due inquiry

Because this statutory path constituted an "efficacious alternative remedy," the Court reasoned that it was not inclined to interfere with the lower authorities' orders via a writ

It held that the petitioner must pursue the specific statutory remedy provided under the M.P. Land Revenue Code

The petitioner was granted liberty to file a fresh application under Section 115 of the M.P. Land Revenue Code, 1959, before the competent authority

The Court explicitly stated it expressed no opinion on the merits of the factual dispute, leaving all issues open for the competent authority to decide