Ryoti land and revenue jurisdiction: statutory occupancy rights arose, but rent and ejectment suits lay only before the Revenue Court.

Admission to ryoti land was treated as creating statutory occupancy rights by operation of law, and the land was held to be ryoti on the facts showing agricultural use and liability to pay rent. That statutory result did not convert the letting into a lease for more than five years, so section 76 of the Madras Hindu Religious Endowments Act, 1927 was not attracted. A suit by a landholder for arrears of rent and ejectment of a ryot lay exclusively before the Revenue Court under the Madras Estates Land Act, 1908, barring civil court cognizance. The cross-objection could not be decided once civil jurisdiction failed.

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Issues: (i) Whether the suit lands were ryoti lands and the respondent was a ryot entitled to occupancy rights; (ii) Whether the letting of temple lands to the respondent was invalid for want of sanction under section 76 of the Madras Hindu Religious Endowments Act, 1927; (iii) Whether the suit for arrears of rent and ejectment was cognizable by the Civil Court or fell within the exclusive jurisdiction of the Revenue Court; (iv) Whether the High Court could deal with the cross-objection after holding that the Civil Court had no jurisdiction.

Issue (i): Whether the suit lands were ryoti lands and the respondent was a ryot entitled to occupancy rights.

Analysis: The lands were shown to be cultivable lands capable of reclamation and cultivation, and the attempt to treat part of them as tank land was a new factual contention not raised below. The respondent's pleadings and evidence showed a dispute about rent and rate, not a denial of liability to pay rent. The grant of patta and the surrounding circumstances established that the land was held for agricultural purposes under a liability to pay rent.

Conclusion: The lands were ryoti lands and the respondent was a ryot.

Issue (ii): Whether the letting of temple lands to the respondent was invalid for want of sanction under section 76 of the Madras Hindu Religious Endowments Act, 1927.

Analysis: Section 76 invalidates a lease of temple property for a term exceeding five years unless sanctioned. The order granting patta did not fix any term, and the statutory permanent right of occupancy under section 6 of the Madras Estates Land Act, 1908, arose by operation of law from admission to ryoti land, not from a lease for a term exceeding five years. The statutory consequence did not convert the letting into a prohibited long-term lease.

Conclusion: The letting was not hit by section 76 and was valid in law.

Issue (iii): Whether the suit for arrears of rent and ejectment was cognizable by the Civil Court or fell within the exclusive jurisdiction of the Revenue Court.

Analysis: Suits by a landholder for arrears of rent and ejectment of a ryot are assigned to the Collector under the Schedule to section 189 of the Madras Estates Land Act, 1908. In view of the express bar on civil court cognizance, the suit could not be tried by the Civil Court.

Conclusion: The Revenue Court alone had jurisdiction and the plaint was rightly directed to be returned for presentation to the proper court.

Issue (iv): Whether the High Court could deal with the cross-objection after holding that the Civil Court had no jurisdiction.

Analysis: Once the Civil Court was found to lack subject-matter jurisdiction, no question on the merits of the cross-objection could be decided. The High Court ought to have confined itself to the jurisdictional question and return of the plaint.

Conclusion: The order on the cross-objection could not be sustained.

Final Conclusion: The appeal succeeded only to the limited extent of setting aside the order on the cross-objection, while the findings that the lands were ryoti, that the respondent was a ryot, and that the suit lay exclusively before the Revenue Court were left undisturbed.

Ratio Decidendi: Admission to ryoti land gives rise to statutory occupancy rights by operation of law, but that consequence does not itself make the transaction a lease for more than five years requiring prior sanction; further, suits for rent and ejectment of a ryot are barred from civil court cognizance by the special revenue forum created by the statute.

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