The Madras High Court has reaffirmed that revenue authorities cannot treat representations for correction of land records as mere formalities. The judgment mandates a substantive, fair, and time-bound adjudication process when property boundaries or extents are disputed, reinforcing the state’s duty to ensure accurate land documentation under constitutional principles of good governance.
Background & Facts
The Dispute
The petitioner, Marimuthammal @ Kuppayammal @ Kuppammal, claims ownership of a property described in Survey Form No. 158/4, Muthunaickenpatti Village, Omalur Taluk, Salem District. She asserts that the recorded extent of the land in the Unified Digital Record (UDR) patta is erroneously listed as 2.72 acres, whereas the correct area, as per a registered sale deed dated 05.04.1976, is 2.60 acres. This discrepancy affects her rights to use, transfer, and tax assessment of the property.
Procedural History
- The petitioner submitted a formal representation dated 09.12.2025 to the Revenue Divisional Officer and Thasildar, requesting correction of the UDR patta.
- No response or action was taken by the respondents within a reasonable time.
- Faced with administrative inaction, the petitioner filed a writ petition under Article 226 of the Constitution seeking a direction to correct the record.
Relief Sought
The petitioner sought a writ of mandamus directing the respondents to correct the land extent in the UDR patta from 2.72 acres to 2.60 acres, based on the 1976 sale deed and supporting documentation.
The Legal Issue
The central question was whether revenue authorities are obligated to adjudicate representations for correction of land records on their merits, or whether they may lawfully ignore such requests without providing reasons or affording a hearing.
Arguments Presented
For the Petitioner
The petitioner’s counsel, Mr. R. Nalliyappan, argued that the failure to act on the representation amounted to a violation of principles of natural justice and administrative accountability. He relied on the constitutional duty of the state under Article 14 and Article 21 to ensure accurate public records, and cited precedents where courts have held that administrative silence in the face of documented evidence constitutes arbitrariness.
For the Respondent
The Special Government Pleader, Mr. D. Ravichander, accepted notice on behalf of the respondents but did not contest the factual basis of the claim. He conceded that no prejudice would arise from reconsidering the representation, but did not advance any legal argument opposing the correction.
The Court's Analysis
The Court examined the nature of UDR patta records as official public documents under the Tamil Nadu Land Records Modernisation Project. It emphasized that such records are not merely administrative entries but serve as the foundation for property rights, taxation, and land transactions. The Court observed that the petitioner had submitted a registered sale deed as primary documentary evidence, and that the respondents had neither disputed its authenticity nor provided any counter-evidence.
"The State cannot remain a silent spectator to errors in land records that affect the rights of citizens. Where a representation is supported by credible documents, the authority must act, not merely acknowledge."
The Court rejected the notion that correction of land records requires a full-fledged inquiry in every case. Instead, it held that a reasonable opportunity to be heard - particularly for neighboring landowners whose boundaries may be affected - is sufficient to satisfy procedural fairness. The Court clarified that it was not expressing any view on the ultimate correctness of the claim, but only on the obligation to adjudicate it.
The Verdict
The petitioner succeeded. The Madras High Court held that revenue authorities must adjudicate representations for land record correction on merits after affording a hearing to affected parties. The first respondent was directed to pass final orders within 12 weeks of receiving a copy of the order.
What This Means For Similar Cases
Administrative Silence Is Not an Option
- Practitioners must now treat non-response to land record correction requests as a justiciable administrative failure.
- Writ petitions under Article 226 are maintainable where revenue authorities delay or ignore representations supported by documentary evidence.
Documentary Evidence Prevails Over Mere Record Entries
- A registered sale deed or title document submitted with a representation creates a prima facie case for correction.
- Revenue officers cannot rely solely on existing UDR entries to reject claims without examining the supporting documents.
Procedural Fairness Requires Targeted Hearings
- Authorities need not conduct exhaustive inquiries in every case.
- A notice to neighboring landowners and interested parties, with a reasonable time to respond, satisfies the requirements of natural justice.
- Failure to even issue such notices constitutes procedural arbitrariness.
