Where title is disputed, patta proceedings must remain in abeyance pending civil adjudication.

The petitioners, claiming through V.R. Senthilnathan Chettiyar, challenged three revenue proceedings dated 12 June 2025, 10 December 2025 and 9 January 2026 concerning mutation of patta, and sought patta in the names of the legal heirs.

They alleged that the mutations were made at the private respondents’ instance without notice to the existing patta holders.

They relied on a settlement in a partition suit between V.R. Senthilnathan Chettiyar and his brother, asserting that pattas had thereafter been mutated in favour of the respective brothers and their heirs.

The respondents disputed that the settlement covered the properties in question.

1. Whether the Court could determine, in writ proceedings, the parties’ competing claims of title to the properties underlying the challenged patta mutations.

2. Whether the patta proceedings could be remanded to the revenue authorities despite the identified title dispute.

The Court relied on Kuppuswami Nainar v. The District Revenue Officer and Others, 1995 (1) MLJ 426, and Edelweiss Asset Construction Company Limited v. R. Perumalswamy and Others, (2021) 11 SCC 98, for the principle that disputes concerning title to property are not to be adjudicated in patta proceedings or writ proceedings of this nature.

It also applied Rule 4(4) of the Patta Pass Book Act, under which, when a dispute relating to title is noticed, revenue authorities must refrain from proceeding further; patta proceedings may proceed only where the parties consent.

The competing positions turned on whether the settlement between the brothers covered the properties now in dispute, a matter involving contested title that the Court considered unsuitable for determination in writ proceedings.

Because the title dispute was unresolved, the Court held that remanding the matter to the revenue authorities would be inconsistent with Rule 4(4).

It therefore left the parties to establish their rights before the Civil Court and preserved the position of the disputed pattas pending civil proceedings.

It disposed of both writ petitions, directed that the challenged patta proceedings be kept in abeyance, and ordered that no mutation of pattas be made in respect of the lands covered by the impugned pattas, subject to civil proceedings initiated by the parties.

No costs were ordered, and the connected miscellaneous petitions were closed.