State Can't Claim Title Or Mark Land As 'Government Property' Solely Based On Town Survey Register: Telangana High Court

The Telangana High Court has held that the State cannot claim title over a property or erect a signboard declaring it to be "Government land" solely on the basis of entries in the Town Survey Land Register (TSLR) in absence of any substantive material or title documents to support its claim. [2026 LiveLaw (Tel) 95]

The Court observed that TSLR entries are only revenue records and do not by themselves establish title. 

Allowing a writ petition filed by Jyothi Estates, Justice Laxmi Narayana Alishetty observed:

"The State cannot claim title over the subject land merely based on the entries in the TSLRs and thereby, it is not entitled to erect a sign board as 'Government land' in the subject land. The State is at liberty to approach appropriate forum to declare its title over the subject land and subject to the result therefrom, then proceed in accordance with law."

The Court consequently directed the authorities to remove the signboard erected on the petitioner's property.

The petitioner claimed ownership over a 331-square yard property situated at Himayathnagar, Hyderabad, tracing its title to a registered sale deed executed in 1955. It submitted that after a series of transactions and litigation, including a suit for specific performance decreed in its favour and affirmed by the High Court in appeal, the revenue authorities, in June 2020, suddenly erected a signboard on the property declaring it to be Government land.

Challenging the action, the petitioner relied upon a No Objection Certificate (NOC) issued by the revenue authorities in 1998 while granting permission for construction. The NOC recorded that an old building had existed on the property for over 40 years and that the relevant entries were reflected in the Town Survey Land Register.

The petitioner contended that having itself acknowledged the existence of a long-standing private building and issued the NOC, the State could not subsequently claim the property as Government land merely on the strength of TSLR entries.

It further argued that entries in revenue records do not constitute proof of title and relied on the Supreme Court's decision in State of Andhra Pradesh v. Hyderabad Potteries Private Limited.

The State, on the other hand, contended that the property was classified as Government land in the Town Survey Land Register and that the petitioner's predecessors had failed to produce any Government grant. It also argued that the entries in the TSLR had attained finality since they were never challenged within the period prescribed under the Andhra Pradesh Survey and Boundaries Act, 1923.

Rejecting the State's contention, the Court found it significant that the revenue authorities themselves had issued the 1998 NOC after examining the link documents and the Town Survey Land Register, expressly recording that the property contained an old building which had existed for more than four decades.

According to the Court, this conduct amounted to an acknowledgment of the long and continuous possession of private parties over the property.

"The above conduct of respondent authorities amounts to approbation and reprobation, which is impermissible in law," the Court observed.

The Court further reiterated the settled legal position that entries in the Town Survey Land Register are only revenue or survey records and cannot, by themselves, establish title.

Referring to earlier decisions, including G. Satyanarayana v. State of Andhra Pradesh and State of Andhra Pradesh v. Hyderabad Potteries Private Limited, the Court observed that the Government cannot claim ownership over private property merely on the basis of TSLR entries unless it secures an appropriate declaration of title from a competent civil court.

The Court noted that apart from relying on the TSLR entries, the State had not produced any substantive material or title documents in support of its claim over the property.

On the contrary, the NOC issued by the authorities themselves evidenced private possession and enjoyment of the land for several decades.

Holding that the State's action could not be sustained, the Court directed respondent authorities to remove the signboard erected on the petitioner's property.

At the same time, the Court clarified that the Government would be at liberty to approach the appropriate forum for declaration of its title and thereafter proceed in accordance with law depending upon the outcome of such proceedings.

Case Title: Jyothi Estates v. State of Telangana & Ors.

Case No.: W.P. No. 11401 of 2020

Appearance: Sri Janardhan Goud Sunkari for the petitioner; Assistant Government Pleader for Revenue for the respondents.

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Citation: 2026 LiveLaw (Tel) 95