Mutation entries cannot decide tenancy or fragmentation breaches; revenue authorities must record the entry and refer the dispute elsewhere.

Revenue mutation entries are fiscal records and do not by themselves create or extinguish title, so a revenue authority cannot finally decide whether a transfer breaches tenancy or fragmentation laws. Its role is confined to recording the mutation under the land revenue law, while any apparent breach of another enactment must be referred to the competent authority under that statute. Where a registered sale deed prima facie raises such a conflict, the entry may be recorded with an express note that it remains subject to the other authority's decision. The mutation order was modified accordingly, and the Mamlatdar was directed to reconsider the matter after hearing the parties.

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Issues: Whether the revenue authority, while dealing with mutation of land revenue entries, can itself decide alleged breach of other enactments such as tenancy or fragmentation laws, or whether it must confine itself to recording the entry and refer the controversy to the competent authority under the other statute.

Analysis: Revenue entries serve a fiscal purpose and do not by themselves confer or extinguish title. However, where a registered transfer appears prima facie to violate another enactment or affect rights governed by that enactment, the revenue authority cannot finally determine the breach under the Land Revenue Code. Its jurisdiction is limited to the revenue record. The proper course is to record the mutation based on the registered sale deed with an express clarification that the transaction appears prima facie to be in breach of the other law, and to refer the matter to the authority competent under that law. The mutation may then remain subject to the decision of that competent authority.

Conclusion: The orders of the revenue authorities were not wholly sustainable, and were modified so that the Mamlatdar must reconsider the mutation in accordance with law, after hearing the parties, and may act on the basis of the above limitations and reference procedure.

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