Tarachandra v. Bhawarlal 2025 INSC 1485 - Will - Mutation - MP Land Revenue Code
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Madhya Pradesh Land Revenue Code, 1959 - There is nothing in the 1959 Code proscribing acquisition of rights in land through a will. As a sequitur, if a will is set up, the application for mutation based thereupon will have to be considered on merits and it cannot be rejected merely because it is based on a will. (Para 15) Mutation - Mutation does not confer any right, title or interest on a person. Mutation in the revenue records is only for fiscal purposes , therefore, where there is no serious dispute raised by any natural legal heir, if any, of the tenure holder, in absence of any legal bar, mutation based on a will should not be denied as it would defeat the interest of Revenue. (Para 19)
Case Info
Tarachandra v. Bhawarlal & Anr.; 2025 INSC 1485.
Key case details
- Case name: Tarachandra v. Bhawarlal & Anr.
- Neutral citation: 2025 INSC 1485
- Coram: Manoj Misra, J.; Sanjay Karol, J.
- Judgment date: December 19, 2025
Caselaws and citations
- Ranjit v. Smt. Nandita Singh & Others, 2021 SCC OnLine MP 3410.
- Anand Choudhary v. State of Madhya Pradesh & Others, 2025 SCC OnLine MP 977 (Full Bench).
- Jitendra Singh v. State of MP & Others, 2021 SCC OnLine SC 802.
Statutes/laws referred
- Madhya Pradesh Land Revenue Code, 1959: Sections 109, 110, 111, 257(a).
- Madhya Pradesh Bhu‑Rajasv Sanhita (Bhu‑Abhilekhon Mein Namantaran) Niyam, 2018.
- Hindu Succession Act, 1956.
- Constitution of India: Article 227.
