Section 15(b) revision cannot adjudicate disputed title or land identity requiring civil determination.

The petitioner sought correction of the Record of Rights (ROR) for Hal Plot No. 2288, claiming that she had acquired land from Sabik Plot No. 2038 through two registered sale deeds dated 27 November 1989 and 30 May 1990.

The Commissioner, Land Records and Settlement, dismissed her revision under Section 15(b) of the Orissa Survey and Settlement Act, 1958, finding that the lands covered by those deeds corresponded to Hal Plots Nos. 2289 and 2296, not the disputed Plot No. 2288.

The petitioner challenged that decision by writ petition.

1. Whether the petitioner established that the land covered by her sale deeds corresponded to Hal Plot No. 2288, warranting correction of its ROR entry

2. Whether the Commissioner could determine the petitioner’s claim where doing so required resolving disputed land identification and competing claims of title

Section 15(b) of the Orissa Survey and Settlement Act, 1958 empowers the revisional authority to examine the correctness of ROR entries, but the ROR neither creates nor extinguishes title, and the authority’s jurisdiction does not extend to adjudicating disputed questions of title (*Pradeep Kumar Behera v. Commissioner of Land Records & Settlement*, 2014 SCC OnLine Ori 520).

Where a claim under Section 15(b) requires adjudication of competing rights arising from registered transactions and determination of title, the dispute belongs before the competent Civil Court (*Judhisthir Routray v. Uttam Bewa*, 2026 SCC OnLine Ori 1438).

The Sabik plot was correlated during settlement with four Hal plots. The settlement materials showed that the petitioner’s deeds related to Hal Plots Nos. 2289 and 2296, while Plot No. 2288 was recorded in the private opposite parties’ names.

The Commissioner had considered the deeds, settlement records, A.S.O.’s report, Jamabandi entries and Yadast; the petitioner demonstrated neither that the correlation finding was perverse nor that material evidence had been ignored.

Since her claim required establishing that the deeded land was Plot No. 2288 and potentially resolving competing title claims, it exceeded the scope of Section 15(b).

The Court dismissed the writ petition without costs. It left the petitioner at liberty to approach the competent Civil Court for declaration of her rights and consequential reliefs.