Public auction land and writ interference: recitals and revenue records showed purchase for price, so protective transfer law did not apply.

Land described in a grant certificate was held not to be a granted land under the Karnataka Scheduled Castes and Scheduled Tribes (Prohibition of Transfer of Certain Lands) Act, 1978, because its recitals, read with the darkhast register extract and Form I, showed purchase in a public auction for a price. The Court applied the principle that a document must be construed by its substance and recitals, not its title alone, and on that basis found Section 4 inapplicable. It also held that certiorari or supervisory jurisdiction does not extend to disturbing concurrent factual findings absent jurisdictional error or grave injustice, so interference was rightly refused.

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Issues: Whether the land in question was a granted land so as to attract the Karnataka Scheduled Castes and Scheduled Tribes (Prohibition of Transfer of Certain Lands) Act, 1978, and whether the High Court was justified in declining interference with the concurrent factual findings.

Analysis: The decisive question was the true nature of the transaction reflected in the grant certificate and connected revenue records. Though the document was styled as a certificate of grant, its recitals, supported by the darkhast register extract and Form I, showed that the land had been sold in public auction in 1948 for a stated price. A document must be construed from its recitals and substance, not from its title alone. On that basis, the authorities correctly held that the land was purchased for a price and was not a granted land within the meaning of the protective statute or the relevant land grant rules. The scope of certiorari and supervisory jurisdiction does not extend to correcting a mere finding of fact unless there is jurisdictional error or grave injustice.

Conclusion: The land was not a granted land, Section 4 of the Act was not attracted, and the High Court rightly refused interference with the concurrent factual findings.

Final Conclusion: The appeal failed on the core factual and legal issue and the dismissal of the writ petition was sustained.

Ratio Decidendi: A land shown by its recitals and revenue records to have been purchased in public auction for a price is not a granted land, and concurrent factual findings to that effect are not ordinarily open to interference in writ jurisdiction.

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