Suo motu revisional powers must be exercised within a reasonable period even when fraud is alleged.

The private petitioners (Srinivasmurthy and the legal representatives of Chikka Doddaiah) had their names recorded in the revenue records (RTC) for several decades—specifically since 1965-66 and 1984-85

The Tahsildar, alleging that the original land grants were forged or fabricated, moved the Special Deputy Commissioner (SDC) to initiate suo motu proceedings under Section 136(3) of the Karnataka Land Revenue Act, 1964, to delete these names

The SDC dropped the proceedings, finding no truth in the Tahsildar's claims

Subsequently, while the petitioners were seeking survey-related actions (phodi/durasth), the Joint Director of Land Records (JDLR) passed orders directing the Tahsildar to remove the petitioners' names from the RTCs, accepting the State's contention that no valid grants existed

The private petitioners challenged the JDLR's orders, while the State challenged the SDC's orders dropping the revision proceedings

1. Whether the Joint Director of Land Records (JDLR) has the jurisdiction under the Karnataka Land Revenue Act to direct the Tahsildar to delete or discontinue names from the Record of Rights (RTC)

2. Whether the revenue authorities can exercise suo motu power to delete revenue entries after a lapse of three to four decades, especially when fraud is alleged

Sections 127 to 129 (Chapter XI) of the Karnataka Land Revenue Act, 1964, which governs the 'Record of Rights' and vests jurisdiction in the Tahsildar, Assistant Commissioner, and Deputy Commissioner, excluding Survey Settlement Authorities like the JDLR

The court applied the principle of "reasonable time" for the exercise of revisional powers, as established by the Supreme Court in Mohamad Kavi Mohamad Amin v. Fatmabai Ibrahim (1997) 6 SCC 71 and Joint Collector Ranga Reddy District v. D. Narsing Rao (2015) 3 SCC 695

These precedents hold that even where fraud is alleged, discretionary or revisional power must be exercised within a reasonable period to avoid uncertainty and protect third-party rights

The Court observed a clear statutory demarcation between Chapter XI (Record of Rights) and Chapter V (Survey Settlement) of the Act.

Since the JDLR is a Survey Officer under Chapter V, the Court held they acted without jurisdiction by issuing directions regarding revenue entries, which are exclusively handled by officers under Chapter XI

The Court also noted a violation of natural justice as the JDLR passed the impugned orders without hearing the aggrieved parties

On the issue of delay, the Court found that the mutation entries had stood for 30–40 years

Following the Joint Collector Ranga Reddy District ruling, the Court reasoned that the State cannot "tamper with mutation entries" after decades, as doing so would trample upon third-party rights and interests created over time

The Court further criticized Tahsildars for initiating such proceedings without a motion from the Revenue Department, describing such actions as "high-handed"

The Court dismissed the writ petitions filed by the State (WP Nos. 24112/2018 and 24113/2018), thereby upholding the SDC’s decision to drop the revision proceedings

The Court held that the JDLR lacks jurisdiction to order the deletion of names from revenue records and that the State cannot initiate proceedings to correct revenue entries after an inordinate delay of 3–4 decades

The Tahsildar was directed to restore the names of the khatedars within six weeks