Mutation entries based on a registered sale deed should be retained subject to pending civil proceedings, not cancelled outright.

A registered sale deed ordinarily supports mutation in the revenue record, and revenue entries are only fiscal in nature without conferring title. The Gujarat HC noted that revenue authorities cannot conclusively decide the validity of a transaction under another enactment or adjudicate disputes reserved for the competent civil forum. Where a prima facie objection exists and civil proceedings are pending, the proper course is to retain the mutation entry with an express qualification that it remains subject to the outcome of those proceedings. The cancellation of the mutation entries in toto was therefore not justified, and the entries were directed to continue with that clarification.

---

---

Issues: Whether a mutation entry made on the basis of a registered sale deed could be cancelled in toto by the revenue authorities, or whether it ought to be continued in the revenue record with a clarification that it would remain subject to the outcome of pending civil proceedings.

Analysis: A registered sale deed normally gives rise to a right requiring mutation in the revenue record, while revenue entries serve only fiscal purposes and do not by themselves confer title. The revenue authority cannot finally determine the validity of a transaction under other enactments or adjudicate disputes that fall within the jurisdiction of the competent civil or statutory forum. At the same time, if the authority finds a prima facie issue of breach under another enactment, the proper course is to retain the mutation entry with an express qualification and leave the underlying dispute to be decided by the competent forum.

Conclusion: The cancellation of the mutation entries in toto was not justified. The entries were directed to continue in the revenue record with a clarification that they would remain subject to the outcome of the pending civil suit.

Ratio Decidendi: A revenue authority dealing with mutation entries based on a registered sale deed may not conclusively adjudicate disputed validity under another enactment, and where such dispute is pending elsewhere, the entry should ordinarily be maintained subject to the outcome of those proceedings.

---