Suo motu revision cannot indirectly reverse unchallenged revenue appellate orders that have attained finality.

The dispute concerned agricultural land at village Sarangi, claimed by the State as property of Shri Laxmi Narayan Temple and by the respondents through their predecessor, Chunnilal.

The respondents relied on historical revenue entries and their family’s recorded cultivation; the State maintained that the Temple was the Bhumiswami and that the respondents’ entries as Adhipati Krishak were unauthorised.

A Naib Tehsildar ordered deletion of the respondents’ names. The SDO and Additional Collector subsequently made orders adverse to the State, including restoration of the respondents’ entries and remand for proceedings under Section 57(2) of the M.P. Land Revenue Code. The State did not appeal those orders.

In later suo motu proceedings, the Additional Commissioner set them aside and upheld deletion of the respondents’ names. The Board of Revenue quashed that order, prompting the State’s writ petition.

1. Whether the Board of Revenue’s order setting aside the Additional Commissioner’s suo motu revisional order disclosed an error warranting interference under Articles 226 and 227 of the Constitution.

2. Whether the Additional Commissioner could, through suo motu revision under Section 50 of the M.P. Land Revenue Code, indirectly reverse earlier orders that the State had not challenged by appeal or revision.

Section 50 of the M.P. Land Revenue Code confers revisional authority to examine, among other things, whether a subordinate revenue officer exercised jurisdiction illegally or with material irregularity; the Court considered the provision in assessing the suo motu proceedings.

Section 115 concerns correction of wrong or unauthorised land-record entries, while Section 114 identifies the records of rights as land records; the Court also referred to these provisions in the context of the respondents’ entries.

Revenue entries serve a fiscal purpose and do not, by themselves, confer title; title disputes are for a competent civil court, as stated in Suraj Bhan v. Financial Commissioner.

Under Shalini Shyam Shetty v. Rajendra Shankar Patil, supervisory jurisdiction under Article 227 is limited and is not an appellate jurisdiction; interference is justified for jurisdictional excess, patent perversity, or manifest failure of justice, not merely because another view is possible.

The Court also referred to the Board of Revenue’s decision in Manak Chand v. State of M.P. for the proposition that suo motu revision should not be used at the State’s direction to revisit an order that was not appealed.

The Court noted that the SDO’s and Additional Collector’s orders had not been challenged by the State through the prescribed appellate or revisional process; instead, those orders were later reversed through suo motu proceedings initiated following a complaint and an administrative direction.

It upheld the Board’s conclusion that this course was not maintainable under Section 50.

The revenue record also contained distinct Khata Nos. 105/1 and 105/2: the Temple was apparently associated with the former, while the respondents’ claim related to the latter. That distinction supported the Board’s view that the Additional Commissioner’s order was inconsistent with the available material.

Given the limited scope of review under Articles 226 and 227, the Court found no basis to disturb the Board’s decision.

It dismissed the State’s writ petition, leaving the Board’s order quashing the Additional Commissioner’s suo motu revisional order undisturbed.