The Supreme Court on Friday brought clarity to a long-running dispute over land records, restoring a mutation entry based on a registered will and overturning a Madhya Pradesh High Court order that had favoured succession under inheritance law. The courtroom discussion stayed rooted in a practical question many villagers face: can land records be updated on the strength of a will, or must heirs always come first?
Background
The case arose from agricultural land in Mouza Bhopali, Madhya Pradesh. The original tenure holder, Roda alias Rodilal, passed away in November 2019. Tarachandra, the appellant, approached the Tehsildar claiming rights under a registered will executed by Rodilal in 2017.
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The revenue authorities accepted the will and allowed mutation, but made it clear that this entry would be subject to the outcome of any civil suit. Things took a turn when Bhawarlal, who claimed possession over one of the survey numbers based on an unregistered agreement to sell, challenged the mutation. While the Sub-Divisional Officer and the Commissioner upheld the Tehsildar’s order, the High Court interfered and directed that names of legal heirs be entered instead, relying on an earlier precedent.
Court’s Observations
Hearing the appeal, the Supreme Court closely examined the Madhya Pradesh Land Revenue Code and the 2018 mutation rules. The bench noted that the law does not prohibit mutation on the basis of a will. “There is nothing in the Code proscribing acquisition of rights in land through a will,” the bench observed, adding that mutation is only a fiscal entry and does not decide ownership once and for all.
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The judges pointed out that none of the natural legal heirs had questioned the will. The only objection came from a third party whose claim rested on an unregistered sale agreement and alleged possession. In such circumstances, the Court said, the High Court should not have brushed aside concurrent findings of the revenue authorities without identifying any serious legal flaw. The bench also reminded that disputes over title or the genuineness of a will are meant for civil courts, not summary mutation proceedings.
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Decision
Allowing the appeal, the Supreme Court set aside the High Court’s order and restored the mutation in favour of Tarachandra based on the registered will. At the same time, the Court clarified that the mutation entry would remain subject to any final decision by a competent civil or revenue court in pending proceedings.
Case Title: Tarachandra v. Bhawarlal & Anr.
Case No.: Civil Appeal No. 15077 of 2025 (arising out of SLP (C) No. 22439 of 2024)
Case Type: Civil Appeal (Land Mutation / Revenue Records)
Decision Date: December 19, 2025
