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Supreme Court of India· 02 September 2026

Is the allotment of City Title Survey numbers by a Revenue/Survey Officer an order of a Revenue Court?

M.R.R. Setty (Dead), by LRs v. Government of Karnataka and others
2026 INSC 944
Coram: Justice Sanjay Kumar · Justice Sanjeev Sachdeva
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Answer

No. Section 24 treats a Revenue Officer as a ‘Revenue Court’ while enquiring into or deciding a question arising for determination between the State Government and any person or between parties to any proceedings. The allotment of CTS numbers in 1974 was not such a determination but merely an administrative exercise, and was not quasi-judicial in nature; the amended Section 25 and its proviso, including the inherent power to review within six months on discovery of new and important matter, are therefore of no avail.

Headnote

Karnataka Land Revenue Act, 1964 — s.56(3) proviso — s.56(1) — s.52 — s.25 — s.24 — Power of revision — Three-year limitation — Record of rights — City Title Survey numbers — Karnataka Land Revenue Act, 1964 — s.56(3) proviso — Revision beyond three years — Power without mooring in the statute — Held: Revisional power over an order against which no appeal has been preferred may be exercised only within three years from the date of that order; invocation of the power decades later is without any mooring in the statute and vitiated in its very inception. (¶16) Karnataka Land Revenue Act, 1964 — s.52 — Limitation Act, 1963 — Application confined to appeals — Held further: Section 52 applies Sections 4, 5 and 12 of the Limitation Act, 1963 to appeals alone. Those provisions cannot be smuggled in to negate and defeat the limitation prescribed by the proviso to Section 56(3). (¶11) Karnataka Land Revenue Act, 1964 — s.24 — s.25 — Allotment of CTS numbers — Administrative, not quasi-judicial — Held further: Allotment of City Title Survey numbers by a Revenue/Survey Officer is merely an administrative exercise and not quasi-judicial; it cannot be equated with an order of a Revenue Court, so the amended Section 25 and its proviso are of no avail. (¶13) Karnataka Land Revenue Act, 1964 — s.56(1) — Enquiry on a time-barred notice — Interference before any adverse order — On facts, held: A party cannot be required to participate in an enquiry founded on power invoked well beyond the prescribed limitation merely because no adverse order has yet been passed. Appeals allowed; the notice quashed. (¶16, 17)

In the Court's own words
Paragraph 13This proviso is now sought to be pressed into service, by relying on the latter portion thereof in the context of discovery of new and important matter or evidence which was not within the knowledge of the Revenue Court when the earlier order was made. In this regard, we may note that Section 24 notifies Revenue Officers, not below the rank of a Tahsildar, while exercising power under the Act of 1964 or under any other law in force to enquire into or to decide any question arising for determination between the State Government and any person or between parties to any proceedings, to be a ‘Revenue Court’. However, the allotment of CTS numbers by a Revenue/Survey Officer in the year 1974 cannot be equated with exercise of power by a Revenue Court under Section 24, as it was not a determination of any question arising between the State Government and any other person or between parties to any proceedings. It was merely an administrative exercise undertaken by such Revenue/Survey Officer and was not quasi-judicial in nature. Therefore, the amended Section 25 and its proviso are of no avail to the Government.
Acts & Sections
s.56(3) Karnataka Land Revenue Act, 1964s.56(1) Karnataka Land Revenue Act, 1964s.52 Karnataka Land Revenue Act, 1964s.25 Karnataka Land Revenue Act, 1964s.24 Karnataka Land Revenue Act, 1964

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Also decided in this judgment
Whether the exercise of jurisdiction under Section 56 of the Karnataka Land Revenue Act, 1964, on the basis of a complaint made by a third party, was sustainable in the light of the limitation prescribed therein?Can the Limitation Act, 1963 be invoked to extend the three-year period for revision under the Karnataka Land Revenue Act, 1964?Must a party participate in an enquiry ordered on a time-barred notice merely because no adverse order has yet been passed?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections