Ramesh Das (Dead) Thr. Lrs. v. State of Madhya Pradesh & Ors.
Background
The plaintiff claimed that a temple (Shri Ram Mandir) in a Madhya Pradesh village was his family's private property, built by his forefathers who were also hereditary pujaris, and sued for a declaration of title and an injunction after the Sub-Divisional Officer tried to auction the land. The trial court ruled in his favour, but the first appellate court reversed that decision, finding no document of title was produced, and the High Court upheld the reversal in second appeal, holding no substantial question of law arose.
Decision Breakdown
The Supreme Court agreed with the lower appellate court and High Court that the plaintiff had failed to produce any document of title to the land and that revenue records alone (which in any case were in the temple's name, with his father recorded only as "Manager/Pujari," not owner) do not create ownership rights. The Court distinguished a precedent relied on by the plaintiff (Narsingh Mandir Chikhalda) because that case involved a registered gift deed and a temple itself as the claimant, unlike here where an individual claimed personal ownership of what the records showed as temple ("Inam Devasthan") property. Finding no substantial question of law had actually arisen, the Court held the second appeal was rightly dismissed by the High Court and dismissed the present appeal too, with no order as to costs.
Lesson Learnt
Revenue/land records (such as Khasra entries) are evidence of possession or management, not proof of ownership: a claimant seeking a declaration of private title must produce an actual document of title (such as a sale or gift deed), especially when contesting land recorded as temple or trust property.