Factual Matrix 

In the instant Matter of Thokchom Tembi Devi v. Kangjam Inaobi Chanu,  a writ petition filed in accordance with Article 227 of the Indian Constitution challenging the decision of the Presiding Officer of the Revenue Tribunal in Manipur to reject the revision of the mutation order made by the Sub-Deputy Collector Patsoi. In October 2015, the petitioner, who is the only owner of the property, borrowed Rs. 2,000 from the respondent for personal purposes. The respondent received a mortgage on the farmland as collateral for the loan. For mortgage purposes, the respondent obtained the petitioner’s signatures. In a case involving mutation, the land was changed into the respondent’s name. Under Section 95 of the Manipur Land Revenue and Land Reforms Act, 1960, the petitioner objected to the mutation decision for a 0.7225-acre area, but the revision petition was denied.

Conclusion of Court

The plea was denied by Manipur High Court Single Judge Bnech Justice  Guneshwar Sharma, who also maintained the decision of the Revenue Tribunal that the Revenue Court lacks the authority to review the validity of the sale document and cannot hear arguments on its legality.

The Court held that a Civil Court with appropriate jurisdiction should resolve the issue of contesting a registered sale deed instead of referring it to a Revenue Court. The court ruled that the Revenue Tribunal was correct in dismissing the revision petition and that the Revenue Court lacks the authority to review the validity of the sale deed, hence the sale deed’s legality cannot be contested there. As a result, the Court denied the petitioner’s request for a revision.

CASE NAME – Thokchom Tembi Devi v. Kangjam Inaobi Chanu, CRP No.15 of 2023