Writ jurisdiction cannot resolve disputed grant authenticity and title claims requiring factual proof.

The petitioners claimed through a chain of registered conveyances originating from a 1962 grant of 8.26 acres in Survey No. 72, Huttanahalli Village, to Papamma. The land was later assigned a new survey number; subsequent purchasers obtained a decree for specific performance and a sale deed, and the petitioners purchased the property in 2020.

The State disputed the genuineness of the original grant. In 2021, the Deputy Commissioner allotted land to GAIL for a public purpose, and possession was handed over.

The petitioners challenged the allotment and sought mutation, phodi and durasth, relying also on an earlier High Court direction to consider their predecessors’ representation.

A separate civil suit seeking an injunction against GAIL’s officers was pending.

1. Whether the Deputy Commissioner’s 6 April 2021 order allotting the disputed land to GAIL, and the subsequent handover of possession, should be quashed in the petitioners’ favour.

2. Whether the petitioners could obtain mutation and directions for phodi and durasth in writ proceedings when the State disputed the original grant and the petitioners’ claimed title.

The Court considered the Karnataka Land Revenue Act, 1964 and the rules made under it as the basis for the Deputy Commissioner’s allotment of land for a public purpose; it identified no specific statutory provision.

Relying on State of Kerala v. M.K. Jose, (2015) 9 SCC 433, the Court applied the principle that disputed questions of fact—here, the genuineness of the grant and the subsequent conveyances—should be established in an appropriate proceeding rather than resolved in writ proceedings.

It held Hemalatha (D) by LRs v. Tukaram (D) by LRs & Ors., 2026 Supreme (SC) 89, inapplicable to the circumstances of this case.

The petitioners’ claimed title depended on the 1962 grant and a succession of later transactions, but the State disputed the grant’s authenticity. The Court also noted that phodi and durasth had not been carried out since the claimed grant, and that the 2008 survey-number changes had not been challenged.

Given these unresolved factual questions, the Court declined to determine title or grant the consequential revenue-record relief in writ jurisdiction. It also found no basis to interfere with the Deputy Commissioner’s allotment to GAIL for a public purpose, made under the land-revenue framework.

It reserved liberty to the petitioners to establish their rights over the land in a manner known to law.