Vishwasrao Satwarao Naik and Ors. v. State of Maharashtra
Background
A large landholder was found, in earlier ceiling proceedings under Maharashtra's land ceiling law, to hold surplus land beyond the then-permissible limit, with part of his land excluded as "pot kharab" (uncultivable) land. After the law was later amended to lower the ceiling limit, his heirs had to file a fresh land return; in the fresh assessment, the proportion of land classified as uncultivable "pot kharab" land turned out to be much smaller than in the earlier round, resulting in more land being declared "surplus" and liable to be handed to the State. The family argued this was inconsistent with the earlier proceedings and challenged it before the Revenue Tribunal and the High Court, both of which rejected their claim.
Decision Breakdown
The Supreme Court held that revenue records carry a presumption of truth, and while that presumption is rebuttable, it was the family's burden to produce evidence, such as the earlier or later revenue records, showing the "pot kharab" classification was wrong or inconsistent between the two rounds of proceedings. The family had failed to produce any such evidence and had, in their own fresh return, initially claimed an even smaller area as uncultivable than what the authorities ultimately found. Finding no merit in the appeal, the Court upheld the lower findings and dismissed the case.
Lesson Learnt
In land ceiling and revenue disputes, official land records are presumed accurate unless the person challenging them actually produces evidence to rebut that presumption: simply asserting an inconsistency with an earlier proceeding, without proof, is not enough to succeed.