Suo motu revisionary powers must be exercised within a reasonable period to avoid unsettling long-standing revenue entries.

The petitioner, an agricultural laborer holding a valid certificate issued by the Mamlatdar, purchased agricultural land via a registered sale deed on August 3, 2007

Mutation Entry No. 2189 was recorded and certified by revenue authorities on November 2, 2007

Ten years later, on June 16, 2017, the District Collector, Botad, issued a consolidated show-cause notice (No. RO/suo-moto-revision/Case No. 15/17) to the petitioner and several others, alleging that the transactions lacked prior permission from competent authorities and were in contravention of statutory provisions

The petitioner challenged this notice under Article 226 of the Constitution, contending it was issued after an inordinate delay and lacked specific particulars

1. Whether the revenue authority can exercise suo motu revision powers after a lapse of ten years from the date of certification of mutation entries

2. Whether a consolidated show-cause notice covering multiple independent transactions across different villages without specific particulars is legally sustainable

The Court primarily applied the principle of "reasonable period" for the exercise of suo motu powers where no statutory limitation is prescribed.

It relied on State of Gujarat v. Patel Raghav Natha (1969), which established that power must be exercised within a reasonable time determined by the facts of the case

It further applied Bharatbhai Naranbhai Vegda v. State of Gujarat (2016), which held that even "void" transactions cannot be unsettled after an inordinate delay, especially if rights have vested or the delay is unexplained

The Court also emphasized that a show-cause notice must contain specific grounds to satisfy the principles of natural justice

The Court observed that while the statute does not prescribe a fixed limitation for suo motu revision, it is settled law that such power must be invoked within a reasonable timeframe

In this case, the ten-year delay between the 2007 certification and the 2017 notice was deemed inordinate and unexplained

The Court noted that the Collector failed to provide specific allegations regarding the petitioner’s particular transaction; instead, the authority issued a "generalized" consolidated notice for multiple parties and different parcels of land

Applying the precedents in Bharatbhai Vegda and Bhanji Devshibhai Luhar, the Court reasoned that allowing the authority to unsettle a decade-old transaction—where the petitioner had maintained the land status—would be contrary to the interests of justice and equity

The High Court allowed the petition and quashed the impugned show-cause notice No. RO/suo-moto-revision/Case No. 15/17 dated June 16, 2017. Rule was made absolute