1910 Settlement Register of Travancore – Basic Record of Land Matters

Taken from: Land Tenures, and History of Land Derivation, in Kerala

Saji Koduvath, Advocate, Kottayam.

Revenue Settlement Registers of Travancore in 1910, Basic Record of Land Matters

The Kerala High Court held in Mohandas v. Santhakumari Amma, 2018-3 KLT 606 as under:

  • “We notice that, a new survey and settlement was undertaken in the erstwhile Travancore State for the purpose of putting in place a sound Revenue administration. Accordingly, it appears that a complete survey and reassessment of the entire State ’embracing an accurate measurement, demarcation, mapping and valuation of properties of every description and a registration of titles, as the basis of a sound Revenue Administration’ was carried out. On the basis of such a statement a proclamation was issued by the Maharaja of Travancore on 14th Kumbhom 1061 corresponding to 24th February 1886.”

Also Read:

If Settlement Register says Government Land, Petitioner to Establish Title

In Vallikunnil Janaki Amma v. Sree Amruthamangalam Kshethram Moorthi, Kozhikode, 2014-1 KHC 57; 2014-1 KLJ 367; 2014-1 KLT (SN) 26, Kerala High Court, held as under:  

  • “18. Even though Ext. A2 is only an extract of the Settlement Register/  Adangal extract which may not by itself prove or confer title to a party in whose name the property stood registered, it can be accepted as evidence of title when there is no contra evidence. Admittedly it is adjacent to Amruthamangalam temple. The temple compound and this suit property which is adjacent to the temple are shown to be of Amruthamangalam Devaswom as per revenue record. In these circumstances, the contention that this property did not and does not belong to the temple/Devaswom cannot be sustained at all.”
  • “20. Therefore, though the entries in the Settlement Register or patta granted are not by themselves document of title, in the absence of any other documents showing better title, the entries in the Settlement Register can be relied upon to uphold the title set up in this case. The same is the view taken by this Court in Narayanan Nambiar v. Raman Chettiar, 1969 KLT 449.
  • Relying on these decisions, it was held by a Division Bench of this Court in Kunhettan Raja v. Kutty Anujan Thampuran, (RFA 120/1991 D/d. 6.10.2003) :
  • “The learned counsel for the plaintiffs has argued that Adangal is a reliable record. The learned counsel invited our attention to page 130 of the book by name Land Systems in British India written by B.H. Baden-Powell,volume No. III, wherein the value of Settlement Register is stated. It is stated that under Ryotwari system every registered holder of the land is recognised as its proprietor. The importance of Settlement Register was considered by P.R. Sundara Aiyar in the book Malabar & Alyasanthan Law, 1922 Edition. In paragraphs 172, 173 and 174 at pages 284 to 288 the method of preparation of Settlement Register is referred. It is to be noted that the Re-survey Settlement was effected between 1932 and 1934 and this book was written long prior to that period in the year 1922. At page 287 of the book, the author had referred to a decision of the Madras High Court in A.S.284 of 1898, in which it was held that these documents can be admitted in evidence in proof of possession and these accounts may be admitted as evidence of title under Section 13 of the Evidence Act. The learned author had referred to Madras Land Registration Act (Act 3 of 1896). This enactment deals with the preparation of Settlement Registers. It shows that before preparing the Settlement Register, an enquiry was conducted by the collector and the persons, whose name is entered in the register, shall be deemed to be proprietors subject to the right of other persons interested to challenge that entry”.
  • (Referred to in: Kunhimangalam Devaswam v. State of Kerala (2022 KHC OnLine 7354), 6 April, 2022, Anil K. Narendran, J. and Chitharanjan v. State of Kerala, WP(C) No, 25830/2010,24.01. 2025, Harisankar V. Menon, J.)

In Sahana Industries v. State of Kerala, in WP(C) 20520/2021 (2021 KHC OnLine 7110), Kerala High Court (Devan Ramachandran, J.) held (October 11, 2021) as under:

  • “… If the Settlement Register shows this land to be Government land, then certainly, the petitioner is obliged to establish their title over the property through competent documents”. (Referred to in: Chitharanjan v. State of Kerala, WP(C) No. 25830/2010, 24.01. 2025, Harisankar V. Menon, J.)

In Chitharanjan v. State of Kerala, WP(C) No. 25830/2010 (2025:KER:5422) 24.01. 2025 (Harisankar V. Menon, J.) it is pointed out as under:

  • “7. …. In the settlement register at Ext. R1(a), there is no dispute that the entire properties under old Survey No. 2211 having an extent in excess of 107 Acres are shown as “puramboke“….
  • 8…. As regards the petitioner in WP(C) No. 25830 of 2010 also, the title is traceable to some documents of the Attingal Sub Registry of the yeas 1959, 1957 and 1061. But, it is categorically found that even in these documents, there is no mention as to the receipt of pattayam with respect to the property in question.
  • 11. …. As already noticed, the settlement register describes the property as “Puramboke”. … In view of the discussions made above, I am of the opinion that the contentions raised by the learned Senior Government Pleader with respect to the malpractices committed, cannot be brushed aside.
  • 13….. However, I notice that WP(C) No.25830 of 2010 the entry with respect to the Settlement Register is to be considered at first, which admittedly is against the petitioner. The case of the State is that some foul play is carried out subsequently at the instance of those interested and therefore, the subsequent entries cannot be acted upon.
  • 14. On the other hand, the learned Government Pleader relied on Vallikunnil Janaki Amma and Ors. v. Sree Amruthamangalam Kshethram Moorthi, Kozhikode and Anr. [2014 (1) KHC 57], which laid down the principle with respect to the acceptability/relevance of the Settlement Register. As already noticed, I have found that the Settlement Register describes the property under old Survey No. 2211 as “Puramboke”. To the same effect is the judgment of a learned Single Judge in WP(C) No. 20520 of 2021 dated 11.10.2021. This Court further notices the judgment of the Apex Court in Suraj Bhan and Ors. v. Financial Commissioner and Ors. [(2007) 6 SCC 186] which held that mere entry in the revenue records does not confer title on a person. As already noticed, in view of the entries in the Settlement Register, the requirement of an appropriate assignment cannot be lost sight of.”

In Travancore Devaswom Board v. Mohanan Nair M.N.,  (2013) 3 KLT 132, (T.R. Ramachandran Nair, J ; A.V. Ramakrishna Pillai, J), it is observed as under:

  • “18. …. The land register as well as the settlement register will establish the plea of the Board that the property having an extent of 2.26 acres is Temple property. Thus, Section 27 of Act of 1950 is clearly attracted and the property is clearly Devaswom property.”
  • “51. As far as the property herein is concerned, the land register and the settlement register produced herein are relevant. The property having the entire extent of 2.26 acres is described as ”kavu” (holy grove) in the settlement register. In the land register also it is described as ”kshethram irippu sthalam” (property where the temple is situated). No other document or other evidence is there to prove the contrary. Therefore, these documents will definitely show that the item of property will fit in with the requirement of Section 3(1)(x) of the Act.”
  • “75. … Apart from that, in the light of Section 27 of the Travancore Cochin Hindu Religious Institutions Act and in the light of the settlement register and land register, the property is described as Temple puramboke and not Government puramboke. Further Government lands are covered by the exemption u/s 3(1)(x) of the Land Reforms Act and therefore he cannot claim any fixity of tenure. There is no claim by the Government here to the property.”

Is Settlement Register A Public Record

In Poddar Plantations Limited, v. Thekkemariveettil Madhavi Amma, ILR 2014-1 Ker 813, it is observed that the settlement register may be a public record. It is held as to the same as under:

  • “70. There could be no dispute that the court has the power to take judicial notice of public records. Assuming that the settlement register referred to by the Tribunal is a public record, it is not as if the contents of the settlement register cannot be disputed. Parties should get opportunity to challenge correctness of the contents of the document. The 2nd defendant did not get that opportunity. Hence the Tribunal was not correct in relying on the settlement register as referred to in its order.”

In Oriental Insurance Company Ltd. v. Poonam Kesarwani , (2010) ACJ 1992, the Division Bench of Allahabad High Court said that the State Register of Driving Licences is a public record; for, it can be inspected by any person.

Settlement Register (Adangal) as Mentioned in Kerala VO Manual

Clause 280 in Chapter 25 of the Kerala Village Office Manual (included in Land Revenue Manual  Volume  VI) refers to ‘Settlement Register (Adangal)’. 

Clause 280 says:

  • 1. Settlement Register is a Permanent Register.
  • 2. It is also called “Adangal” or “A Register”.
  • 3. There will be 2 Annexures (or Supplements) to the Settlement Register.
  • 4. The 1st Annexure (or Supplement) Registers kept in the Village Offices contain all matters as to the lands subsequently surveyed (that were not surveyed at the time of Settlement).
  • 5. The 2nd Annexure (or Supplement) Registers kept in the Village Offices contain all changes subsequent to settlement (and also the changes to the land mentioned in the 1st Annexure Registers).
  • 6. The serial number of the entries in the 2nd Annexure Registers shall be noted in the remark column of the Settlement Register.

In Travancore, after 1910, no “Settlement” or “Settlement Register” has been made 2018(2) KLT 369 (HML case, Para 111).

  • ‘Adangal’ is a term originally used in the erstwhile Madras State. It is a Revenue Record based on the survey conducted.

In Cl. 281, Basic Tax Register (BTR) is specifically referred to.  It is described as a “Permanent Register”.

  • Note: Clause 280 in Chapter 25 of the Kerala Village Office Manual referred to the Supplements to the Settlement Register because the Re- Survey is not completed throughout the State. In the Areas where the Re-Survey is conducted and BTR is made, the Supplement Registers have no application.
  • But, even in places where Re-Survey is effected, the 1910 Settlement Register (“A-Register”) is to be maintained (as a ‘permanent register’).

It is also noteworthy that no Settlement is made after 1910.

As a matter of fact, in Village Offices the Registers are maintained with the name “A-Register” containing the particulars in BTR; and “B-Registers”, to incorporate the subsequent changes made in the land (after preparation of the BTR) though they are not specifically directed in Kerala Village Office Manual.  It is exactly corresponds to the “second additional register” stated in Cl. 281 of the Village Office Manual which is directed to be maintained in addition to the 1910 Settlement “A-Register”

  • Note: Settlement A to D Registers are (originally) referred to in the Travancore Land Revenue Manual, Vol. III (1915), in Cl. 712 and 713, respectively.
  • But Clause 280 in Chapter 25 of the Kerala Village Office Manual recognises the Settlement Register alone as ‘Permanent Register’.

As regards the authority of “Manuals” it is observed in State of Kerala v. Navaneeth Krishnan, ILR 2023-3 Ker 686; 2023-4 KLT 756, as under:

  • “The Apex Court in Lalita Kumari v. Govt. of U.P. [2013 (4) KHC 552: 2014-2 SCC 1] in paragraph 79 considered the binding authority of the CBI Crime Manual. It was held that CBI Crime Manual is not a statute, it is only a set of administrative orders issued for internal guidance of the CBI officers and it cannot supersede the provisions of Cr. P.C. It was further held that in the absence of any indication to the contrary in the Cr. P.C itself, the provisions of the CBI Crime Manual cannot be relied upon. A Single Bench of this Court in Santhosh T. A. And Another v. State of Kerala [2017 (5) KHC 107] dealt with the binding authority of the Kerala Excise Manual under the Abkari Act. It was held that the Manual contains only executive instruction and has no force of a statutory provision.”
  • In Jacob v. State of Kerala, 1964 KLT 359, it had been held (Vaidyalingam, J.), as under:
  • “The instructions or directions contained in the Travancore Land Revenue Manual … have not been given by virtue of any rule making power vested in the. Government, either under the provisions of the Travancore Revenue Recovery Act or under the provisions of the Travancore-Cochin Revenue Recovery Act. …. If that is so, the directions contained in the Travancore Land Revenue Manual can only be considered to be in the nature of executive directions and they will have no force whatsoever, especially in view of the fact that S.6 of the Travancore-Cochin Revenue Recovery Act, 1951 lays down that the sale of immovable property of the defaulter shall be “in the manner provided hereinafter”.

Chitta and Adangal in Madras

Chitta: Chitta is a revenue document maintained in Taluk office. It contains extent of land, name of owner and the type of land (wet/dry, irrigated/rainfed, etc.).

Adangal: Adangal is also a revenue record, prepared after surveying the land, that contains details about the land, such as the ownership, extent, classification of land, and details of cultivators. It is taken as a document for showing the ownership and possession of land. (See: D. Rajamanickam v. M.  Pasupathiammal, 2019-2 Mad LJ 208; N. Chandrasekaran v. Arulmighu Thiruvatteeswarar Thirukkoil, 2020-1 LW 631; 2020-5 Mad LJ 227)

History of Settlement and Adangal Register in Malabar

In Sukapuram Sabhayogam v. State of Kerala, AIR 1963 Ker 101, it was pointed out with reference to the Madras District Gazetteer, Malabar as regards the history of settlement (1900 -1904) and re settlement (1931-1934) and as regards the preparation of Adangal Registers after the settlement as under:

  • “67. In the Madras District Gazetteer, Malabar, by Inis, 1951 Edition, at page 344, it is stated that the settlement was introduced into the eight plain Taluks of Malabar between 1900 and 1904 and the Revenue system of the District has been brought into line with that of the rest of the Presidency, due allowance being made for special local conditions.
  • 68. Dealing with the re-settlement, it is stated in the same Gazetteer, at page 848, that it took place between 1931 and 1934, and that the re-settlement was done because the term of 30 years for which the then existing rates of land assessment were sanctioned had expired between 1929-30 and 1932-33- A list of the taluks giving particulars as to when the last settlement expired and the new settlement came into operation, is also given at the same page.
  • 69. At page 349 of the same book, among the special features of the re-settlement, it is mentioned that the terms “janmabhogam” or “private janmam” were replaced by new holdings and old holdings respectively. That is, in the Adangal Registers etc., maintained after the settlement was introduced for the first time in 1900 and 1904, the lands of all the jenmis appear to have been shown as private janmam but in the re-settlement the register shows them as old holdings.”

Ryotwari Settlement in Malabar Area

In Balmadies Plantations Ltd. v. The State of T.N., AIR 1972 SC 2240 while examining the status of land holders under ryotwari settlement it was pointed out that this system was brought about by Col. Read in 1792 consequent to ceding of territories by Tippu Sultan, as described in the Manual of Administration quoted by Baden-Powell, in Vol. III of Land Systems of British India.

Private Janmam in Malabar Area – Ended By 1934

In Sukapuram Sabhayogam v. State of Kerala, AIR 1963 Ker 101, it is also pointed out that notwithstanding the introduction of the Ryotwari settlement in Malabar area between 1900 and 1904, certain lands were shown as ‘private janmam’ as distinguished from ‘Government Janmam’. And, added as under:

  • “The practice of treating the properties of persons like the petitioner as private janmam has been completely given the go-by, at any rate, after the resettlement during 1931-1934.”

In Land Law in Madras Presidency, BR Chakravarthy, 1927, it is said as under:

  • “The land Revenue settlement in Malabar differed from the ordinary ryotwari settlement in the rest of the presidency, in that in Malabar. The existence of a landlord between the state and the actual cultivator is recognised in the theoretical distribution of the produce, on which the rates of assessment are based.”

The tradition as regards the Malabar-land is pointed out by Chkravarthy as under:

  • “The tradition with regard to Malabar is that the God Parasurama, who created it, granted it to a set of Brahmins to be held by them tax free; that accordingly these Brahmins held and cultivated the lands, without -even the obligation to pay any tax”.

Lands held under Ryotwari tenure after Ryotwari Settlement

In Kannan Devan Hills Produce v. State of Kerala, AIR 1972 SC 2301; 1972-2 SCC 218, it was pointed out that it was held by the Full Bench of the Kerala High Court in Sukapuram Sabhayogam v. State of Kerala, AIR 1963 Kerala 101 that the lands, after 1934, were ‘held under Ryotwari tenure after the introduction of the Ryotwari Settlement in the Malabar area of Kerala State’.

Patta in (Madras) Estates Land Act, 1908

As observed in Secretary of State for India v. T. V.  Raghavachariar, 83 IndCas 1009; 1924 20 LW 815; 1924-47 MLJ 503, patta was not a document of title, or a deed of grant in the erstwhile Madras State. In ‘Land Law in Madras Presidency’, 1927, BR Chakravarthy says that the landholders had to issue pattas (rent deeds) and the ryots had to pay muchilikas (rent) and that they were to be exchanged on ‘yearly basis’. Going by Estates Land Act, 1908 (Sec. 50, 51 and 52), ‘Patta’ was originally a word connected to land-lease. (Government was the largest Landholder).

Rayotwari Patta in Estates Act, 1948

  • Under Sec 11 of the Estates (Abolition and Conversion into Rayotwari) Act, 1948, every ryot would be entitled for Rayotwari Patta.
  • Note: A ryotwari pattadar was not a proprietor of land in its full sense, but only a tenant.

‘Patta’ is issued by Landholder to Ryot, stating rate of Rent

As per Sec. 50, 51 and 52 of the (Madras) Estates Land Act, 1908 ‘Patta’ is a document issued by the landholder (person owning land and entitled to collect rent) to the ryot (person holds ryoti land on condition to pay rent) stating rate of rent, among other things, for the period, usually, one year.

“Record of Rights” in Madras Presidency

In ‘Land Law in Madras Presidency’, 1927, BR Chakravarthy says as regards the first larger step for survey of lands as under:

  • “Record of Rights: The Local Government may make up order directing that a Survey be made and a. Record of Rights prepared by a revenue officer in respect of any estate or part there-of in the following cases.
  • (l) Where an application is made by the landholder or landholders, if there are more than one, and of the ryots;
  • (2) Where the Local Government considers, that the preparation of a record is necessary for securing the rights of the landholder; and of the ryots and for preventing disputes arising between them;
  • (3) Where an estate is managed by the Government or is under the superintendence of the Court of Wards.
  • The first step in the preparation of the Record, will be a survey of the lands under the Madras Survey and Boundaries Act 1897; the next step will be, if the Government so directs, to inquire into the rights and obligations of the ryots and of the landholder in respect of the several holdings. ‘When both these steps are completed, a preliminary record will be made of the results of the inquiries and of the survey by the Revenue Officer in .charge and published in such manner and for such period as the Government may direct. During the period of publication, all objections to any entries or omissions in the Record will be heard and determined by the Revenue Officer himself, in accordance with the procedure prescribed by the Government.”

End Notes

Certified Copies of Public Documents Admissible per se without Formal Proof

Certified copies of the public documents can be proved without formal proof. See:

  • Jaswant Singh v. Gurdev Singh, 2012-1 SCC 425 ,
  • Shyam Lal @ Kuldeep v. Sanjeev Kumar, AIR 2009 SC  3115; 2009-12 SCC 454
  • Harpal Singh and Another v. State of Himachal Pradesh, AIR 1981 SC 361
  • Madamanchi Ramappa v. Muthalur Bojjappa, AIR 1963 SC 1633
  • Rajasthan State Road Trans. Corp. v. Nand Kishore, 2002 ACJ 1564 (Raj)
  • Md. Akbar v. State of A.P., 2002 CrLJ 3167 (And)
  • Collector (L. A. ), South Andaman v. Himangshu Mondal, 2015-2 CalLT 1
  • Arti Meena v. Rajasthan High Court, Jodhpur, 2020-1 SCT 1 (Raj).

In Madamanchi Ramappa v. Muthalur Bojjappa (Gajendragadkar , J.), AIR1963 SC1633; 1964-2 SCR 673, it is held as under:

  • “9. … The document in question being a Certified copy of a public document need not have been proved by calling a witness.”(Referred to in Rangaraju v. Kannayal, 10 Jan 2012, (Mad).

In Harpal Singh and Another v. State of Himachal Pradesh, AIR 1981 SC 361, it is held as under:

  • “3.…  We cannot agree with him for the simple reason that the entry was made by the concerned official in the discharge of his official duties, that it is therefore clearly admissible under Section 35 of the Evidence Act and that it is not necessary for the prosecution to examine its author ” (Quoted in: Manikanta v. State of Karnataka, 2024 Kar HC 21233)

In Shyam Lal @ Kuldeep v. Sanjeev Kumar, AIR 2009 SC  3115; 2009-12 SCC 454, it was observed as under:

  • “25. The findings of the learned District Judge holding Ex. P. 2 to be a public documentand admitting the same without formal proof cannot be questioned by the defendants in the present appeal sinceno objection was raised by them when such document was tendered and received in evidence.
  • It has been held in Dasondha Singh and Others v. Zalam Singh and Others [1997(1) P.L.R. 735] that an objection as to the admissibility and mode of proof of a document must be taken at the trialbefore it is received in evidence and marked as an exhibit.
  • Even otherwise such a document falls within the ambit of Section 74, Evidence Act, and is admissible per se without formal proof“.

In Jaswant Singh v. Gurdev Singh, 2012-1 SCC 425, it is held that certified copy of a public document prepared under Section 76 of the Act, in terms of Section 74 of the Indian Evidence Act, 1872 is admissible in evidence under Section 77 of the said Act, without being proved by calling witness. It is said as under:

  • “9. … To put it clear, the compromise had become a part of the decree which was passed by the court of Sub-Judge Ist Class, Hoshiarpur. Hence, it is a public document in terms of Section 74 of the Indian Evidence Act, 1872 (in short ‘the Act’) and certified copy of the public document prepared under Section 76 of the Act is admissible in evidence under Section 77 of the said Act. A certified copy of a public document is admissible in evidence without being proved by calling witness.

See also the following cases where documents were accepted in evidence and acted upon on the basis of Section 35 Evidence Act:

  • Umesh Chandra v. State of Rajasthan, AIR 1982 SC 1057 (admission forms as also the School’s register)
  • Harpal Singh v. State of Himachal Pradesh, AIR 1981 SC 361 (certified copy of the birth register).

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End Notes

It is Settled – Revenue Records will not confer title

  • Sawarni v. Inder Kaur, (1996) 6 SCC 223
  • Balwant Singh v. Daulat Singh, (1997) 7 SCC 137
  • Suman Verma v. Union of India, (2004) 12 SCC 58; 
  • Gurunath Manohar Pavaskar v. Nagesh Siddappa Navalgund, AIR 2008 SC 901
  • State of AP v. Star Bone Mill & Fertiliser Company, (2013) 9 SCC 319
  • Faqruddin v. Tajuddin, (2008) 8 SCC 12;
  • Rajinder Singh v. State of J&K, (2008) 9 SCC 368; 
  • Narasamma v. State of Karnataka, (2009) 5 SCC 591
  • Municipal Corporation, Aurangabad v. State of Maharashtra, (2015) 16 SCC 689; 
  • T. Ravi v. B. Chinna Narasimha, (2017) 7 SCC 342;
  • Bhimabai Mahadeo Kambekar v. Arthur Import & Export Co., (2019) 3 SCC 191; 
  • Prahlad Pradhan v. Sonu Kumhar, (2019) 10 SCC 259;
  • Ajit Kaur v. Darshan Singh, (2019) 13 SCC 70.
  • Bhimabai Mahadeo Kambekar v. Arthur Import and Export Co. (2019) 3 SCC 191
  • Jitendra Singh v.  The State of Madhya Pradesh (2021 SCC OnLine SC 802) [M.R. Shah,  Aniruddha Bose, JJ.]
  • P.  Kishore Kumar v. Vittal K.  Patkar, 2024-1 CTC 547; 2023-4 CurCC(SC) 278
  • Laxkshmi B. v. Suku, 2024-1 KerHC 380
  • The State of Punjab vs Bhagwantpal Singh Alias Bhagwant Singh, 10 July, 2024: 2024 INSC 518
  • Ram Balak Singh v. State of Bihar, 2024 INSC 360, 01 May 2024 [Pankaj Mithal and Prasanna Bhalachandra Varale, JJ.]

Revenue Records Prove Possession

  • Gurunath Manohar Pavaskar v. Nagesh Siddappa Navalgund, AIR 2008 SC 901 (Revenue record merely raises a presumption in regard to possession)
  • State of AP v. Star Bone Mill & Fertiliser Company, (2013) 9 SCC 319 (Revenue records merely show possession of a person)
  • Zila Panchayat Etah v. Om Prakash Shah, 01 Sep 2017; 2017 0 Supreme(SC) 1418 (There is statutory presumption of correctness of revenue entries which has not been rebutted in the instant case.)
  • Krishnamurthy S.  Setlur v.  O.V.  Narasimha Setty, 2019-9 SCC 488 (Revenue records prove possession)

Survey Authorities Not to decide Title; Only Conclusive proof – Boundaries recorded correctly (when survey was made)

  • Kannan v. Kannan, (1964 KLT 228), 
  • The Cheriyanad Grama Panchayath v. The State of Kerala,  (2019 (5) KHC 699),
  • Venugopalan Nair v. Saraswathy Amma, (2013 (4) KLT 717),
  • Karthyayani v. Balakrishnan, (2014 (2) KLT Suppl. 67 (Ker.),
  • Ibrahim v. Saythumuhammed, (2013 (4) KLT 435)
  • Prahlad Pradhan v. Sonu Kumhar, (2019) 10 SCC 259
  • Achama Alexander v. Asst. Director, Survey and Land Records, 2022 (2) KHC 131: 2022-3 KLT 198.
  • Thomas v. Philip,2022(4) KerHC 451;
  • Elambilan Nani Amma v. Mulavana Antony (K. Babu, J,), 2023-7 KHC 418.

Presumption of Correctness on Entries in the Revenue Record

In Vishwa Vijai Bharti vs Fakhrul Hasan, AIR 1976 SC 1485 it is held as to the presumption of correctness on revenue-records as under:

  • “It is true that the entries in the revenue record ought, generally, to be accepted at their face value and courts should not embark upon an appellate inquiry in to their correctness. But the presumption of correctness can apply only to genuine, not forged or fraudulent, entries. The distinction may be fine but it is real. The distinction is that one cannot challenge the correctness of what the entry is the revenue record states but the entry is open to the attack that it was Made fraudulently or surreptitiously. Fraud and forgery rob a document of all its legal effect and cannot found a claim to possessory title.”

Statutory Presumption of correctness of revenue entries

In Zila Panchayat Etah v. Om Prakash Shah, 01 Sep 2017; 2017 0 Supreme(SC) 1418, it is held as under:

  • “There was absolutely nothing to rebut the Nazul Khasra or the records maintained by the municipality and Zila Parishad. The appellant had pleaded Survey numbers in its written statement very clearly and had adduced evidence in this regard. There was absolutely nothing to discard the documentary evidence adduced by the appellant and rely upon oral ipse dixit evidence of the plaintiff-respondent. There is statutory presumption of correctness of revenue entries which has not been rebutted in the instant case. The plaintiff-respondent was claiming his ownership on the property in question, but no documentary evidence had been adduced on his behalf indicating that they were the owners of the property in question. Absence of entry in relevant documents of ownership also negates case of plaintiffs. Thus the property in question was clearly under the ownership of the Government.”

Revenue records can support claim of ownership when corroborated

In State of Haryana & Anr. Vs. Amin Lal(Vikram Nath,  Prasanna B.VaraleJJ),2024-4 CurCC(SC) 222, it is held as under:

  • Revenue records are public documents maintained by government officials in the regular course of duties and carry a presumption of correctness under Section 35 of the Indian Evidence Act, 1872. While it is true that revenue entries do not by themselves confer title, they are admissible as evidence of possession and can support a claim of ownership when corroborated by other evidence.

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