Mutation entry does not creat title

The Supreme Court of India has consistently held that mutation entries in revenue records do not create or extinguish title to property, nor do they carry any presumptive value regarding ownership. These entries are primarily for fiscal purposes, such as the payment of land revenue, and do not confer or take away any legal rights, title, or interest in the property.

In several judgments, the Court has clarified this position. For instance, in P. Kishore Kumar v. Vittal K. Patkar (2023), the Supreme Court reiterated that revenue records are not documents of title. It emphasized that merely mutating a name in revenue records does not divest the true title-owners of their rights. The Court further noted that in a title dispute, the burden lies on the plaintiff to establish a better title, and pointing out flaws in the defendant’s title is insufficient. Revenue documents, being fiscal in nature, do not suffice to prove ownership to a high degree of probability.