In Tarachandra v Bhawarlal [2025 INSC 1485], the Supreme Court held that there is no legal bar to carrying out the mutation of land records on the basis of a Will. Such mutation cannot be denied merely because the claim is founded on a testamentary document.
The Court reiterated that mutation entries do not confer any right, title, or interest in property and are meant only for fiscal and revenue purposes. Therefore, where no serious dispute is raised by any natural legal heir, mutation based on a Will should not be denied.
The Supreme Court relied on the judgment in Jitendra Singh v. State of MP and Others , which held that if there is a dispute regarding the title—particularly when the mutation entry is sought on the basis of a Will—the party claiming the title or right must approach the appropriate civil court to establish their claim.
