Mutation revision must be exercised within a reasonable time; revenue authorities cannot test transactions under a separate statute.

Revisional control over mutation entries must be exercised within a reasonable time, and a belated revision of a certified entry is beyond jurisdiction. Revenue authorities in RTS proceedings are also confined to the correctness of the mutation record and cannot test the validity of a transaction by applying another enactment; any challenge under that separate law must be decided by the authority empowered under it, after which the revenue record may follow. On these principles, cancellation of the mutation entries could not be sustained, and the impugned revision orders were quashed.

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Issues: (i) Whether revisional powers over mutation entries could be exercised after an unreasonable delay; (ii) Whether revenue authorities in RTS proceedings could determine the validity of a transaction by reference to another enactment.

Issue (i): Whether revisional powers over mutation entries could be exercised after an unreasonable delay.

Analysis: The revisional power under the revenue code and the corresponding rule was held to be exercisable only within a reasonable time. The Court applied the binding rule that such power cannot be used after expiry of a reasonable period, and treated the later revision of a certified mutation entry as beyond jurisdiction because it was exercised long after certification.

Conclusion: The belated exercise of revisional power was invalid and the orders passed in revision could not be sustained.

Issue (ii): Whether revenue authorities in RTS proceedings could determine the validity of a transaction by reference to another enactment.

Analysis: The statutory scheme of mutation and revenue record proceedings confers only limited authority to inquire into the correctness of entries. The Court held that such authorities cannot decide the legality of a transaction on the touchstone of a different statute; if an issue arises under another enactment, it must be decided by the authority constituted under that enactment and the mutation entry can follow that decision.

Conclusion: Revenue authorities lacked jurisdiction to annul the mutation entry on the ground that the underlying transaction was allegedly contrary to another law.

Final Conclusion: The impugned orders cancelling and affirming cancellation of the mutation entries were quashed, and the petitions succeeded with no order as to costs.

Ratio Decidendi: Revisional control over mutation entries must be exercised within a reasonable time, and revenue authorities dealing with mutation records cannot adjudicate the validity of a transaction under a separate statute; that belongs to the authority empowered under that statute.

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