Record-of-rights cannot override urban land ceiling proceedings; passbook implementation was premature while excess land status remained unresolved.

A pattedar passbook carries a statutory presumption of correctness, but record-of-rights entries do not create title and cannot override urban land ceiling restrictions. Where proceedings under the Urban Land (Ceiling and Regulation) Act, 1976 were still pending, the revenue authorities could not be compelled to alter registry entries, split pattas, or issue passbooks in a way that would pre-empt the statutory determination of excess vacant land. The entitlement to implement mutation-related orders depended on the landholder first succeeding in the ceiling proceedings. The writ appeal therefore succeeded to the limited extent that the direction to issue or implement passbooks at that stage was unsustainable.

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Issues: Whether a writ of mandamus could be issued directing implementation of revenue entries and issuance of pattedar passbooks during the pendency of proceedings under the Urban Land (Ceiling and Regulation) Act, 1976.

Analysis: The record of rights does not create title, though a pattedar passbook carries a statutory presumption of correctness. That presumption operates within the framework of the record-of-rights legislation and cannot override the restrictions imposed by the urban land ceiling law. The relevant rules prohibit change of registry or splitting of pattas where such action would contravene the Urban Land (Ceiling and Regulation) Act, 1976. Since proceedings under that Act were pending and the question whether the land was excess vacant land had not been finally resolved, the revenue authorities could not be compelled to implement earlier mutation-related orders in a manner that would pre-empt the statutory determination.

Conclusion: The direction to issue or implement the passbooks at that stage was unsustainable, and the writ appeal succeeded to that extent. Any entitlement to passbooks would arise only after the urban land ceiling proceedings were concluded in favour of the landholder.

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