LexStreak
Read free →
Supreme Court of India· 10 September 2026

Do revenue entries such as Jamabandis and Khasra Girdawaris create or extinguish title?

BHAG SINGH (D) THR. MAHANT KASHMIR SINGH v. BASANT KAUR (D) THR. LRS. AND OTHERS
2026 INSC 983 · CIVIL APPEAL NO. 1718 OF 2016
Coram: Justice Prashant Kumar Mishra · Justice Shree Chandrashekhar
🔖 Save this judgment🔔 Follow s.100 Code of Civil Procedure, 1…📬 Get today's judgments
View the original judgment PDFFree to read. To download it — or the LexStreak typeset copy with the headnote and Points of Law — create an account; downloads are part of the Pro plan.
Answer

Revenue entries such as Jamabandis and Khasra Girdawaris are relevant evidence of possession but do not create or extinguish title.

No. Revenue entries are relevant evidence of the nature and continuity of possession, but they neither create nor extinguish title to immovable property; the question of ownership must be determined on the basis of substantive evidence establishing the source of title.

Headnote

Code of Civil Procedure, 1908 — s.100 — Second appeal — Property — Revenue records — Title — Dedication — Adverse possession — Evidence — Revenue records — Proof of possession, not title — Held: Revenue entries such as Jamabandis and Khasra Girdawaris are relevant evidence of possession but do not, by themselves, create or extinguish title, which must be established through substantive evidence of its source. (¶23) Property — Dedication to a religious institution — Burden of proof — Held further: The burden of establishing a valid dedication of property to a religious institution lies on the party asserting it, which must show a clear and unequivocal intention to permanently divest ownership. (¶25) Limitation Act, 1963 — Adverse possession — Hostile animus required — Held further: Adverse possession requires actual, open, continuous and hostile possession denying the true owner's title, not mere long possession from a lawful or permissive origin. (¶28, 31) Code of Civil Procedure, 1908 — s.100 — Concurrent findings — Misapplication of law — Held further: Concurrent findings of fact are not immune from interference in second appeal where vitiated by a misapplication of law or an erroneous understanding of settled legal principles; appeal dismissed, the finding of adverse possession set aside. (¶40, 43, 44)

Headnote

You've used your free headnotes this month

The answer above and the Court's own paragraphs stay free. LexStreak's full headnote on this judgment needs an account — a free one opens it again.

Create my free account
In the Court's own words
Paragraph 23At the outset, it is necessary to bear in mind the distinction between proof of possession and proof of title. Revenue records, including Jamabandis and Khasra Girdawaris, are undoubtedly relevant pieces of evidence for determining the nature and continuity of possession. They neither create nor extinguish title, nor can they, by themselves, constitute conclusive evidence of ownership. The consistent view of this Court has been that entries in revenue records are primarily maintained for fiscal purposes and are admissible as evidence of possession, but they do not confer title to immovable property. The question of ownership must ultimately be determined on the basis of substantive evidence establishing the source of title. [See: Suraj Bhan and Others vs. Financial Commissioner and Others[^4]; Vadiyala Prabhakar Rao and Others vs. Government of Andhra Pradesh and Others[^5]]
Acts & Sections
s.100 Code of Civil Procedure, 1908

One judgment a day. That's the whole habit.

Read the full text of BHAG SINGH (D) THR. MAHANT KASHMIR SINGH v. BASANT KAUR (D) THR. LRS. AND OTHERS — and get the Supreme Court's output as a five-minute daily read, with plain-language headnotes and the questions each judgment settles.

Create my free account

Free forever plan · 30 seconds · data stays in India

Open the full judgment →

Also decided in this judgment
Does the burden of establishing a valid dedication of property to a religious institution lie on the party asserting it?Does adverse possession require actual, open, continuous and hostile possession denying the true owner's title, not mere long possession from a lawful or permissive origin?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections