Writ interference with concurrent revenue orders requires patent illegality, perversity, or jurisdictional error.

The petitioners claimed that agricultural land at Village Pamakhhedi, Tehsil Sironj, District Vidisha, was ancestral property inherited from their grandfather, Nanda, and that area entries relating to Survey Nos. 253, 355 and 257 were erroneous.

The Sub-Divisional Officer rejected their correction application on 01.08.2024; the Collector dismissed their first appeal on 11.08.2025; and the Additional Commissioner dismissed their second appeal under Section 44(2) of the Madhya Pradesh Land Revenue Code, 1959, on 31.03.2026.

The petitioners challenged all three orders under Article 226, alleging that the authorities had failed to properly consider historical revenue entries and had relied on a defective inquiry report.

1. Whether the concurrent revenue orders rejecting the petitioners’ application for correction of revenue entries disclosed an error warranting interference under Article 226 of the Constitution

2. Whether the petitioners established a specific procedural or other legally recognised infirmity in the inquiry or orders sufficient to set them aside

Article 226 permits judicial review of administrative and quasi-judicial decisions where, for example, there is jurisdictional error, violation of natural justice, patent illegality or perversity; it does not make the High Court a further appellate authority for reassessing disputed factual material.

Section 44(2) of the Madhya Pradesh Land Revenue Code, 1959, provides the statutory second-appeal route invoked by the petitioners.

Revenue entries are primarily fiscal and administrative: they do not, by themselves, create or extinguish title, and a substantive dispute concerning ownership or inheritance must be established before the competent forum in accordance with law.

The Court held that the petitioners’ claim went beyond correction of an apparent clerical or arithmetical mistake because it implicated the recording of names and competing claims to the land.

Their reliance on selected historical entries and disagreement with the revenue report did not demonstrate that the authorities’ conclusions were manifestly contrary to the record or otherwise legally infirm.

Having pursued the statutory appeals, the petitioners still failed to establish jurisdictional error, procedural violation, patent illegality or perversity justifying writ intervention.

The Court also clarified that the revenue-entry proceedings did not determine title, leaving any maintainable substantive claim to be pursued before the competent forum.

It clarified that its observations did not finally adjudicate title or other substantive civil rights, and left the parties at liberty to pursue remedies available in law; no order as to costs was made.