Compromise in revenue proceedings cannot create title without registration, and orders passed without jurisdiction are void.

A compromise recorded in revenue correction proceedings did not by itself confer lawful title to immovable property when it operated only within the revenue framework and not as a transfer of ownership. Because the compromise created rights for the first time in the land, registration was mandatory, and without registration no title could arise. The Deputy Commissioner's order was also without legal effect because it was passed while the 1972 Act was under suspension and the relevant power was not saved. Estoppel could not override these statutory defects. The respondent's claim therefore failed on title, registration, and jurisdiction.

---

---

Issues: (i) Whether the compromise dated 18.12.1975 conferred lawful title on the respondent over the suit land; (ii) whether the compromise and the Deputy Commissioner's order required registration; (iii) whether the Deputy Commissioner had jurisdiction to act while the 1972 Act was under suspension; and (iv) whether estoppel could bar the appellants' challenge.

Issue (i): Whether the compromise dated 18.12.1975 conferred lawful title on the respondent over the suit land.

Analysis: The compromise was recorded in proceedings for correction of revenue entries under the agrarian reform regime and, on its own terms, operated within the statutory framework governing revenue records and personal cultivation. The statutory definitions of owner and personal cultivation were expansive, and the proceeding was directed to revenue recognition rather than transfer of proprietary title. The land was also found to be orchard land, which stood outside the relevant statutory definition of land. An acknowledgment in the compromise could not, by itself, amount to a transfer of ownership.

Conclusion: The compromise did not convey lawful title to the respondent.

Issue (ii): Whether the compromise and the Deputy Commissioner's order required registration.

Analysis: The transaction was not a family arrangement, as it was entered into with a tenant and not solely among family members. The respondent founded his claim on the compromise itself and not on any antecedent title. Where a compromise creates rights, title, or interest for the first time in immovable property, compulsory registration is attracted. The compromise and the consequential order, having been made in a revenue proceeding and not a court proceeding, fell outside the relevant exception and required registration to have legal effect.

Conclusion: Registration was mandatory and, absent registration, no title could arise in favour of the respondent.

Issue (iii): Whether the Deputy Commissioner had jurisdiction to act while the 1972 Act was under suspension.

Analysis: The compromise and the order were passed during the period when the 1972 Act was suspended. The suspension provisions saved only specified sections and related matters, and the appeal and revision power invoked in the proceeding was not among the protected provisions. An authority acting without inherent jurisdiction under a special statute renders its order a nullity, and such defect cannot be cured by consent of the parties.

Conclusion: The Deputy Commissioner lacked jurisdiction and the order had no legal effect.

Issue (iv): Whether estoppel could bar the appellants' challenge.

Analysis: Equity cannot override statutory requirements. Since the respondent's claim failed for want of a valid transfer and for want of registration, and because the authority's order was without jurisdiction, estoppel could not sustain the decree against the appellants. The statutory position prevailed over any equitable plea.

Conclusion: Estoppel did not apply against the appellants.

Final Conclusion: The decree protecting the respondent's claim to the suit land was set aside, and the appellants succeeded on the legal issues of title, registration, and jurisdiction.

Ratio Decidendi: A compromise recorded in revenue correction proceedings cannot confer title to immovable property where it creates rights for the first time, requires registration, and is acted upon by an authority lacking jurisdiction under a suspended statute; such an order is a nullity and cannot be sustained by estoppel.

---