Reasonable-time limit on suo motu revisional power; long unexplained delay can defeat exercise of authority.

Statutory suo motu revisional power described as exercisable "at any time" is not unlimited; absent an express limitation period, it must be exercised within a reasonable time, assessed on the facts and circumstances, especially where delay disturbs settled rights or later proceedings have attained finality. Fraud, if properly pleaded and proved, may justify action from the date of discovery, but only on an adequate record. The commentary also notes that validation certificates issued by the Tahsildar were not invalid merely because a later ceiling regime existed, and that cancellation was sustained on the facts where fraud was specifically established.

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Issues: (i) Whether the Collector's suo motu power under Section 50-B(4) of the Andhra Pradesh (Telangana Area) Tenancy and Agricultural Lands Act, 1950 could be exercised at any time, or only within a reasonable time. (ii) Whether the validation certificates issued by the Tahsildar were liable to be cancelled on the facts of the case.

Issue (i): Whether the Collector's suo motu power under Section 50-B(4) of the Andhra Pradesh (Telangana Area) Tenancy and Agricultural Lands Act, 1950 could be exercised at any time, or only within a reasonable time.

Analysis: The expression "at any time" was held not to authorise an unlimited, unguided or arbitrary exercise of revisional power. Where a statute confers suo motu revisional authority without prescribing a limitation period, the power must be exercised within a reasonable time, to be judged on the facts and circumstances of each case. The Court emphasised that long and unexplained delay, especially where third-party rights have intervened and other proceedings have attained finality, would unsettle settled positions and create uncertainty. Fraud, where properly pleaded and established, may justify action within a reasonable time from discovery, but that basis was not established on the record in the first group of appeals.

Conclusion: The Collector's suo motu power under Section 50-B(4) is not exercisable indefinitely and must be exercised within a reasonable time; this issue was decided against the appellants.

Issue (ii): Whether the validation certificates issued by the Tahsildar were liable to be cancelled on the facts of the case.

Analysis: The Court accepted the findings that the applications for validation had been made within the extended period and that the certificates issued by the Tahsildar could not be treated as invalid merely because the later ceiling regime had come into force. The inconsistency contemplated by Section 50-B was held to relate to the ceiling law in force at the relevant time, and not to be expanded by reference to a later enactment. In the second group of appeals, where fraud had been specifically pleaded and established on the record, no ground was made out to interfere with the concurrent factual findings sustaining cancellation.

Conclusion: The challenge to the validation certificates failed on the facts, and the orders cancelling them were upheld where fraud was established; this issue was also decided against the appellants.

Final Conclusion: The appeals did not warrant interference, and the common effect of the decision was to sustain the High Court's approach on the reasonable-time requirement while leaving undisturbed the fact-specific outcomes concerning the validation certificates.

Ratio Decidendi: A statutory power of suo motu revision expressed to be exercisable "at any time" must, absent an express limitation period, be exercised within a reasonable time, assessed contextually, and long unexplained delay may invalidate the exercise of that power.

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