Reasonable-time limits on revisional power protect bona fide purchasers and settled revenue records from belated cancellation.

Revisional power to cancel a supplementary sethwar under Section 166-B(3) is not governed by an express limitation period, but it must be exercised within a reasonable time, especially where settled revenue entries and third-party interests are involved. Mere suspicion of fraud is insufficient to reopen long-accepted records without concrete proof and without first addressing the original assignment and subsequent alienations. The article also notes that purchasers who bought land for consideration from recorded holders, after due enquiry and on the basis of mutated revenue entries, pass books and title deeds, may claim protection as bona fide purchasers for value. On these facts, belated cancellation of the sethwar was impermissible.

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Issues: (i) Whether permission to initiate revisional proceedings for cancellation of the supplementary sethwar under Section 166-B(3) of the Andhra Pradesh (Telangana Area) Land Revenue Act, 1317 Fasli could be sustained after an inordinate lapse of time. (ii) Whether the writ petitioners, having purchased the land from the recorded holders and acted on the revenue entries, were entitled to protection as bona fide purchasers for value.

Issue (i): Whether permission to initiate revisional proceedings for cancellation of the supplementary sethwar under Section 166-B(3) of the Andhra Pradesh (Telangana Area) Land Revenue Act, 1317 Fasli could be sustained after an inordinate lapse of time.

Analysis: The revisional power under Section 166-B is not subject to an express limitation period, but such power must be exercised within a reasonable time. The earlier order dated 02.02.2006 had declined permission on the material then available and had called for fresh, specific grounds if suo motu revision was still considered necessary. The later request and the order dated 09.04.2008 proceeded on essentially the same suspicion without decisive proof of fraud or without first cancelling the original assignment or the subsequent alienations. The Court also noted that mere suspicion, without concrete establishment of fraud, was insufficient to justify reopening long-settled revenue entries and third-party interests.

Conclusion: The belated exercise of revisional power was unjustified and the permission granted for cancellation of the supplementary sethwar could not be sustained.

Issue (ii): Whether the writ petitioners, having purchased the land from the recorded holders and acted on the revenue entries, were entitled to protection as bona fide purchasers for value.

Analysis: The materials showed that the writ petitioners purchased the land for consideration after due enquiry, that their names were mutated in the revenue records, and that pattadar pass books and title deeds were issued. The Court applied the principles governing transfers by an ostensible owner: the transferee must act in good faith and take reasonable care to ascertain the transferor's authority. On the facts, the revenue record, the earlier official actions, and the absence of any definitive finding of fraud against the writ petitioners supported their claim to bona fide purchase. In such circumstances, the attempt to disturb their possession through cancellation of the supplementary sethwar after long delay was impermissible.

Conclusion: The writ petitioners were entitled to protection as bona fide purchasers for value, and the challenged action could not be upheld.

Final Conclusion: The common judgment of the Single Judge was affirmed, and the writ appeals failed because the impugned revisional permission was rightly interdicted in view of unreasonable delay, absence of proved fraud against the writ petitioners, and the protection available to bona fide purchasers.

Ratio Decidendi: Even where no express limitation period is prescribed, revisional power affecting settled property rights must be exercised within a reasonable time, and a transfer made by an ostensible owner for consideration will not be disturbed absent proof of lack of good faith or failure to take reasonable care by the transferee.

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