Natural justice requires notice before adverse mutation of patta and revenue records affecting title claims.

Mutation of patta and revenue records affecting land already standing in a party's name cannot be altered without notice and hearing. Under the Tamil Nadu Patta Pass Book Act, patta entries are prima facie evidence of title and may be modified only in the circumstances permitted by law. Where the change is adverse and the dispute concerns title, the affected person must be given an opportunity to be heard before any correction is made. As no notice was issued before the impugned mutation order, the procedure violated natural justice; the order was quashed and the matter remitted for fresh consideration after hearing both sides.

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Issues: Whether the mutation of patta and revenue records, effected without notice or hearing to the affected party, was liable to be quashed for violation of principles of natural justice.

Analysis: The dispute concerned alteration of revenue entries in respect of land already standing in the appellant's name. The governing scheme under the Tamil Nadu Patta Pass Book Act, 1983 recognises patta entries as prima facie evidence of title and permits modification only in specified circumstances. Even where correction of entries is sought, the affected person must be given an opportunity of hearing before any adverse change is made. On the admitted facts, no notice was issued by the first respondent before passing the impugned order, and the alteration was made on the basis of an enquiry conducted by the Tahsildar. Since the core objection was one of title and the appellant had not been afforded a proper hearing, the procedure adopted was inconsistent with natural justice.

Conclusion: The impugned mutation order was unsustainable and was quashed. The matter was remitted for fresh consideration after affording both sides an opportunity of hearing.

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