Revenue mutation cannot decide title or inheritance; substantive ownership rights must be determined by a civil court.

Revenue mutation proceedings are confined to correcting fiscal entries and do not confer title. Questions of ownership, inheritance and other substantive proprietary rights cannot be conclusively decided by revenue authorities or a High Court in such proceedings. The authorities exceeded their permissible scope by treating the mutation dispute as one of title and succession. The matter had to be left open for determination by a competent civil court, and the mutation entry could not finally decide ownership or inheritance.

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Issues: Whether the revenue authorities and the High Court could decide questions of ownership, title and inheritance in proceedings confined to a mutation entry in the revenue records, and whether such substantive rights had to be left to adjudication by a competent civil court.

Analysis: The dispute before the revenue authorities arose only from the mutation entered after the death of the original allottee. The controversy, therefore, was limited to the correctness of the revenue entry. Revenue records are relevant only for fiscal purposes and do not confer title. Questions relating to ownership, inheritance and substantive proprietary rights cannot be conclusively determined in such proceedings. The authorities and the High Court exceeded the permissible scope by entering into the larger issue of title and succession instead of confining themselves to the mutation entry.

Conclusion: The matter had to be left open for determination by a competent civil court, and the mutation proceedings could not finally decide title or inheritance.

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