Revenue Entries Do Not Confer Title; Mere Presence Of Name In Record Creates No Legal Right: HP High Court
Mehak Aggarwal
10 Jan 2026 9:30 AM IST
The Himachal Pradesh High Court held that the mere name of a person in the revenue record does not confer ownership or create any enforceable right in respect of immovable property.
The Court further remarked that revenue entries are maintained for fiscal purposes and cannot be treated as proof of title.
Justice Virender Singh remarked that: “Merely name of defendant No.1 appeared in the revenue record is of no value as the revenue record is not the proof of title.”
The plaintiff filed a civil suit seeking a permanent prohibitory injunction to restrain the defendants from transferring, alienating, encumbering, or creating third-party rights on land in District Kangra.
In response, the defendant No.1 filed an application for rejection of the plaint under Order VII Rule 11 CPC, contending that the plaintiff herself admitted in the plaint that the suit property had already been settled in favour of defendant No.2 by an earlier and therefore no cause of action survived.
The Court observed that she pleaded that defendant No.1 had executed a settlement deed in favour of defendant No.2 in much prior to the settlement deeds relied upon by her.
Thus, the Court remarked that once the plaintiff herself accepted the existence of the earlier settlement so her apprehension against defendant No.1 became inadmissible.
The Court stated that “The contradictory stand taken by the plaintiff, in the plaint, cannot be said to be inconsequential, but, the same demonstrates that the plaintiff is having no cause of action to file the present suit.”
The Court concluded that the plaintiff should have filed a 'suit for declaration', challenging the terms and conditions of the settlement deeds if she was aggrieved by the restrictions or terms contained in the settlement deeds.
Case Name: Beverley Singh v/s Tejinder Singh & Another
Case No: OMP No.385 of 2023 in Civil Suit No.29 of 2023.
Date of Decision: 28.11.2025
For the Plaintiff: Mr. Neeraj Gupta, Senior Advocate with Mr. Ajeet Pal Singh Jaswal, Advocate.
For the Defendants: Mr. R.L. Sood, Senior Advocate with Mr. Arjun Lal, Ms. Sanjeevani Sood and Mr. Aakash Thakur, Advocates, for defendant No.1/applicant. Mr. Nitin Thakur, Advocate for defendant No.2/Nonapplicant.