Suo Motu revisional powers cannot be exercised to unsettle vested property rights after an unreasonable lapse of time.

The Petitioner company was declared Bhumiswami of 5.225 hectares of land in Village Mahalgaon via an order dated 25.11.2010 passed by an In-charge Tehsildar.

This followed a 2007 order recording Petitioner’s possession in revenue records.

Years later, based on a third-party complaint, the Collector initiated suo motu revision and set aside the 2010 order, declaring the land as Government property.

After a remand from the Board of Revenue for violation of natural justice, the Collector passed the impugned order dated 26.07.2019, reiterating that the Petitioner (a company) could not acquire Bhumiswami rights and that the In-charge Tehsildar lacked jurisdiction.

Petitioner challenged this via writ petition after an interim appeal was dismissed as non-maintainable in 2021.

1. Whether the writ petition is barred by the doctrine of delay and laches given the gap between the 2019 order and 2026 filing.

2. Whether a private limited company is a "person" capable of acquiring Bhumiswami rights under the M.P. Land Revenue Code, 1959.

3. Whether an officer holding "current charge" as In-charge Tehsildar is competent to exercise quasi-judicial statutory powers.

4. Whether the exercise of suo motu revisional jurisdiction after a lapse of several years was legally sustainable.

Section 2(31) of the M.P. General Clauses Act, which defines "person" to include companies.

The Full Bench decision in Ranveer Singh v. State of M.P. (2010) regarding the 180-day limitation for suo motu revision.

The doctrine of separate corporate personality as established in Salomon v. Salomon and Bacha F. Guzdar v. CIT.

The principles from Dehri Rohtas Light Railway Co. v. District Board and Shiv Dass v. Union of India, establishing that delay is a rule of discretion, not an absolute bar, especially where jurisdictional errors or manifest injustice exist.

The Court rejected the delay objection, noting the Petitioner was bona fide pursuing an incompetent appeal and was further protected by the Supreme Court’s COVID-19 limitation extensions.

On merits, the Court held the Collector’s finding that a company cannot be an agriculturist was "manifestly erroneous," as Section 2(31) of the General Clauses Act explicitly includes corporate entities.

The Court clarified that an In-charge Tehsildar exercises all statutory powers of the office unless specifically restricted by the Collector.

The Court found the Collector’s suo motu action was barred by time per the Ranveer Singh precedent, as it was initiated years after the 2010 order without justifying the delay.

The Court observed that historical "Mafi Atiya Sarkar" entries did not prove Government title, especially since the revenue records simultaneously recognized the private ownership of the Scindia family.

The Court allowed the writ petition and quashed the Collector's order dated 26.07.2019, restoring the original order dated 25.11.2010 conferring Bhumiswami rights.

The Court directed the State to correct revenue records within 30 days to reflect the Petitioner’s ownership; no order as to costs.