In Vadiyala Prabhakar Rao & Ors. v. The Government of Andhra Pradesh & Ors [2026 INSC 450], the Supreme Court summarised the legal position regarding Revenue Entries and their effect on the question of title as follows:
- Entries in Revenue Records or Jamabandi serve only a “fiscal purpose”. Their primary function is to enable the person whose name is mutated in the records to pay the land revenue in question.
- A Revenue Record is not a document of title and does not confer any ownership or title upon the person whose name appears in it. Further, mutation does not create or extinguish title and has absolutely no presumptive value regarding title.
- The mere acceptance of municipal or agricultural taxes, or the granting of a bank loan based on these records, does not stop the State from challenging the ownership of the land.
- While they do not prove title, Revenue Records can raise a presumption regarding possession. Maintenance and custody of Revenue Records is the exclusive domain of the Patwari, and it is not uncommon that Revenue Records are often tinkered with by him to suit the exigencies.
- Stray or solitary entries recorded for a single year do not raise a presumption of rights and cannot be relied upon against a long, consistent course of revenue entries in favour of another party.
- The creation of fabricated records in collusion acts as a camouflage to defeat the legal rights of the actual tiller, and the Government is not bound by them.
