AP Rights in Land Act | Revenue Authorities Cannot Adjudicate Title or Alter Entries After 71-Year Delay: Andhra Pradesh High Court

“The rights accrued in favour of the petitioners cannot be set aside resulting in miscarriage of justice... exercise of revisional power after a long lapse of time is unreasonable and oppressive.” — In a seminal ruling, the Andhra Pradesh High Court, comprising Justice R. Raghunandan Rao, has quashed a Joint Collector's order that attempted to alter revenue records after a staggering delay of 71 years, firmly establishing that revenue authorities cannot usurp the jurisdiction of Civil Courts to adjudicate title disputes.

The Factual Matrix: A 71-Year Hiatus

The case arose from a Writ Petition filed by T. Bali Reddy (since deceased) and others, challenging the order of the Joint Collector, Ananthapuramu. The petitioners claimed ownership of approximately 43 acres of land in Julakaluva Village, purchased by their father through registered sale deeds between 1939 and 1951. Their names were mutated in the revenue records, and pattadar passbooks were issued as early as 1988.

However, in 2014—71 years after the initial transactions—the 6th Respondent approached the Tahsildar seeking pattadar passbooks based on a 2014 family partition deed. The Tahsildar and subsequently the Revenue Divisional Officer (RDO) rejected the claim, with the RDO specifically noting that the matter involved complicated questions of title best suited for a Civil Court.

The Joint Collector’s Overreach

Despite the RDO’s reasoned rejection, the Joint Collector, exercising revisional jurisdiction, set aside the RDO’s order in 2017. Relying solely on a report submitted by the RDO during the revision proceedings, the Joint Collector directed the alteration of revenue entries. The High Court found this intervention to be legally unsustainable, noting that the Joint Collector had effectively attempted to decide title on the basis of an administrative report, bypassing the judicial process.

“The revenue authorities could not have entertained any application, after a lapse of 71 years if 1943 is taken into account or more than 26 years if the year-1988 is taken into account.”

Doctrine of Reasonable Time and Settled Rights

Justice Raghunandan Rao placed heavy reliance on the doctrine of reasonable time. Citing the Division Bench judgment in Government of Andhra Pradesh v. Chilla Ramarao and the Supreme Court’s ruling in Joint Collector, Ranga Reddy District v. D. Narsing Rao, the Court reiterated that even where no specific limitation is prescribed for exercising revisional powers, such powers must be exercised within a reasonable timeframe.

The Court observed that entertaining a claim after seven decades unsettles established rights and violates the rule of law. The entries in the Record of Rights carry significant evidentiary value, and allowing them to be challenged after such an inordinate delay would lead to chaos and uncertainty in immovable property rights.

Revenue Authorities vs. Civil Court Jurisdiction

The Court delivered a sharp rebuke regarding the jurisdiction of revenue authorities. It emphasized that under Section 8(2) of the Andhra Pradesh Rights in Land and Pattadar Pass Books Act, 1971, the remedy for a person aggrieved by an entry denying their title is to institute a suit for declaration in a competent Civil Court.

“The 6th respondent having deliberately chosen to approach the revenue authorities... instead of attempting to demonstrate his title and possession over the land, cannot now seek relief under the provisions of the Act, 1971.”

The Bench held that when the RDO had already identified the existence of complicated questions of fact and title, the revenue machinery should have ceased its interference. By attempting to resolve a title dispute through revenue entries, the Joint Collector acted without jurisdiction. The Court concluded that the 6th Respondent’s attempt to bypass the Civil Court by approaching revenue authorities was impermissible.

The High Court allowed the Writ Petition, setting aside the impugned order of the Joint Collector dated 19.09.2017 as arbitrary and void. The Court affirmed that long-standing revenue entries cannot be destabilized by stale claims and that title disputes remain the exclusive preserve of Civil Courts.

Date of Decision: 02/01/2026