Suo motu revisional powers cannot be exercised after unreasonable delay absent exceptional circumstances.

The Trust claimed the disputed land under a trust deed dated 29 October 1949, said to have been registered under the then-applicable Kanoon Registry, Riyasat Gwalior, Samvat 1971.

On 3 July 1974, the Sub-Divisional Officer recognised the Trust’s claim and directed that its name be recorded in the revenue records.

Revenue authorities later reopened the matter and passed orders adverse to the Trust, culminating in directions to record the land as Government land and treat the Trust’s possession as unauthorised.

The Trust challenged those orders under Article 226, contending that the earlier order had been reopened after an unreasonable delay and that the authorities had failed to consider the trust deed and related material.

Separately, applicants seeking to rely on a later order under Section 131 of the Madhya Pradesh Land Revenue Code, 1959, sought intervention; the Court dismissed their application because they had not shown a direct and substantial interest necessary to decide the writ petition.

1. Whether the applicants seeking intervention had a direct and substantial interest making their presence necessary or proper for adjudicating the writ petition.

2. Whether the revenue authorities could exercise suo motu revisional jurisdiction approximately three years after the order dated 3 July 1974, in the absence of an exceptional justification such as fraud or suppression.

3. Whether the subsequent orders founded on that revisional exercise, including the directions to treat the land as Government land and the Trust’s possession as unauthorised, could be sustained.

Under State of Gujarat v. Patil Raghav Natha, (1969) 2 SCC 187, where a statute prescribes no limitation period for exercising revisional power, that power must nevertheless be exercised within a reasonable time; it cannot be used after unreasonable delay to unsettle an order and the position acted upon under it.

The Court also considered the Kanoon Registry, Riyasat Gwalior, Samvat 1971, including Clause 4(4) on the officer exercising the Sub-Registrar’s functions and Clause 9(d) on registrable instruments creating a trust or dedicating property for public religious or charitable purposes.

Revenue entries do not, by themselves, confer title, but may be relevant evidence of possession and the manner in which property was treated.

Article 226 permits review of the legality of the revenue authorities’ exercise of jurisdiction, without requiring the High Court to undertake a comprehensive adjudication of disputed title.

The Court found that the original trust deed bore the endorsement of the judicial officer said to have exercised the Sub-Registrar’s powers under the applicable historical law, and that the deed, revenue entries and 1974 order were material requiring proper consideration.

The 1974 order had not been challenged within a reasonable period, while the subsequent suo motu revisional exercise occurred approximately three years later without any recorded cogent explanation or finding of fraud, misrepresentation or suppression.

Applying Patil Raghav Natha, the Court held that this delay rendered the reopening impermissible; the later orders founded on that exercise could not stand.

The Court did not determine title comprehensively, but held that disputed-title questions did not validate the delayed exercise of revisional power.

The intervenors’ subsequent Section 131 order did not establish the direct and substantial interest required for intervention, and any rights under that order could be pursued in appropriate proceedings.

It allowed the writ petition, quashed the orders dated 21 March 1978, 22 January 1990, 29 June 2002 and 12 February 2007, together with consequential actions treating the land as Government land and the Trust