2026 C L C 407

 2026 C L C 407

[Board of Revenue, Punjab]

Before Rashad Ahmad Khan, Member (Judicial-VIII)

Chaudhary MUHAMMAD UMAR and others ---Petitioners

Versus

SEEMA BEGUM and others ---Respondents

Review No. 48 of 2025 in R.O.R. No. 2010 of 2024, decided on 17th

March, 2025.

Punjab Land Revenue Act (XVII of 1967)---

----Ss.52, 53, 166 & 172(2)(vi)---Specific Relief Act (I of 1877), S.42---

Correction of revenue record sought---Whether jurisdiction laid with

Revenue Authorities or Civil Court---Long standing entries on basis

of valid documents---Effect---Presumption of truth---Scope---Plea of

fraud---Whether a revenue court can cancel a mutation lawfully

entered in the revenue record on the basis of a registered General

Power of Attorney or oral transaction, and construe such mutation

as a clerical or factual mistake on the pretext of alleged fraud---

Respondents, relying on Ss. 166 & 172(2)(vi) of the Punjab Land

Revenue Act, 1967, filed an application before the Additional Deputy

Commissioner (Revenue) for correction of revenue record and

cancellation of mutation after a lapse of more than 26 years of

incorporation of said entries/ mutation, which application was

allowed---Held: Application leading to the cancellation of mutation-

in-question was filed after an inordinate delay of 26 years and was,

therefore, hit by limitation---Said long-standing mutation was based

on a registered General Power of Attorney /GPA (dated 14.07.1982)

which remained unchallenged---The entries carried a presumption

of truth under S.52 of the Punjab Land Revenue Act, 1967, and the

jurisdiction to challenge such entries rested with the civil courts

under S.53, not Revenue Courts---The impugned order failed to

address said jurisdictional limitation and did not acknowledge the

requirement of instituting a declaratory suit as reiterated in S.42 of

the Specific Relief Act, 1877---Furthermore, the petitioners

substantiated that certified copies of the GPA were placed before the

competent authority and that the entire claim of the respondents

lacked bona fide as they remained silent for decades, which was

detrimental---The mandate of S.53 of the Punjab Land Revenue Act,

1967 clearly establishes that the revenue hierarchy acts in execution

of civil rights determined by the Civil Court and cannot function as a

parallel appellate or supervisory body---Had the mutation not been

based on a legal document, a different legal scenario might have emerged, even then, establishing fraud would remain a necessary

legal threshold before any corrective action---It is legally untenable

that a mutation rooted in a legal document had been labeled a

mistake merely to circumvent the procedural rigour of approaching

a civil court---Complete absence of recourse to a civil court to

challenge the legal documents, strips the revenue forum of any

jurisdiction---Revenue courts exercise summary jurisdiction and

lack competence to adjudicate questions of fraud, title, or complex

civil rights arising out of civil litigation---From an equitable

standpoint, the conduct of the respondents also triggered the

doctrines of acquiescence and estoppel---The application of the

respondents involved disputed questions of title and allegations of

fraud, which fell outside the jurisdiction of the revenue hierarchy---

Such matters must be resolved by a civil court---Furthermore, the

principle of acquiescence was attracted as the respondents silence

rendered their belated challenge unsustainable---Revenue

Authorities are creatures of statute and are confined strictly to the

jurisdiction vested in them under the Punjab Land Revenue 1967;

they are no Courts of plenary jurisdiction and cannot venture into

questions that involve adjudication of civil rights, title, or

allegations of fraud, which require framing of issues and recording

of evidences---The respondents relied upon purposive meaning and

interpretation rather than the literal interpretation of Ss.166 &

172(2)(vi) of the Punjab Land Revenue Act, 1967---Section 166 states:

"Clerical or arithmetical mistakes in any decree or order made by

any Revenue Officer, or errors therein from any accidental slip or

omission may, at any time, be corrected by such officer"---A literal

interpretation confines said provision strictly to minor, non-

substantive corrections arising from inadvertent slips or

computational errors---Even under a purposive construction, the

legislative intent behind said section is to maintain procedural

accuracy not to confer authority upon revenue officers to review or

annul entries based on civil court decrees---Likewise, S.172(2)(vi),

which allows "the correction of any entry in a record of right,

periodical record or register of mutation," is designed for routine

administrative corrections---Interpreted purposively, it does not

empower revenue authorities to adjudicate complex disputes

involving title, fraud, or the enforceability of decrees---Such matters

lie exclusively within jurisdiction of Civil Court---Thus, the order

passed by the Additional Commissioner (Revenue), was upheld, and as

a result, the earlier order passed by the Additional Deputy

Commissioner (Revenue), stood set aside ;the respondents might seek

appropriate relief before a Civil Court of competent jurisdiction, if so

desired---Petition was allowed accordingly. PLD 2016 SC 872; 2020 YLR 1776; 2010 YLR 2687; 2014 CLC 1484;

2021 SCMR 1068; 2003 SCMR 1330; 2020 YLR 666; PLD 2012 Lah. 160;

2008 SCMR 1658; 2021 CLC 689; 2021 SCMR 391; 2002 SCMR 1330; 2011

SCMR 222; PLD 1994 SC 336; 2004 SCMR 604, PLD 2020 Lah. 478; PLD

2011 SC 512 and PLD 2010 SC 1 ref.

Chaudhary Muhammad Iqbal and Ijaz Leshari for Petitioners.

Malik Ghazanfar Khalid Saeed for Respondents.

ORDER

RASHAD AHMAD KHAN, MEMBER (JUDICIAL-VIII).---This Review

Petition No.48/2025 in R.O.R. No. 2011/2024, has been filed under

Section 8 of the Punjab Board of Revenue Act, 1957, against the

impugned order dated 29.01.2025, passed by the Member (Judicial-

VIII), Board of Revenue, Punjab, whereby the order dated 29.07.2024,

passed by the ACR, was set aside.

2. Brief facts of the case are that the respondents filed an

application through special attorney Imran Saeed dated 06.07.2010,

before the Deputy Commissioner, Rahim Yar Khan, for correction of

revenue record and cancellation of Mutation No. 310 dated 13.03.1984.

The learned ADCR (Additional Deputy Commissioner, Revenue, Rahim

Yar Khan) accepted the application vide order dated 26.10.2021. The

appeal of the petitioners was accepted by the learned ACR (Additional

Commissioner, Revenue, Lahore) vide order dated 29.07.2024. The

respondents filed Revision Petition No. 2010/2024, which was accepted

by the learned Member (Judicial-VIII), Board of Revenue, Punjab, vide

order dated 29.01.2025. Thus, this petition.

3. The learned counsel for the petitioners stated that the impugned

order has been passed against law and facts, as the controversy of

jurisdiction where longstanding entries exist in periodical records was

not addressed. He argued that the application dated 06.07.2010 was

filed after a lapse of more than 26 years for cancellation of Mutation

No. 310 sanctioned on 13.03.1984, and is barred by limitation. Reliance

was placed on PLD 2016 SC 872.

4. It was submitted that the application was neither signed by Mst.

Seema nor Mst. Lubna, and they never challenged the GPA. Their

mother, Mst. Fahmeeda Begum, passed away 18 years ago, and no

inheritance mutation was sought, which implies that respondents

knew of Mutation No. 310 and raised no challenge during her lifetime.

Reliance was placed on 2021 SCMR 1068, 2003 SCMR 1330, 2023 SCMR

1402, and 2020 YLR 666. 5. It was further alleged that the application dated 06.07.2010 was

filed with mala fide intent to extort money, as on 13.03.1984, other

Mutations Nos. 312-315 were also sanctioned in favour of Imran Saced

and his relatives based on GPA from Zia-ul-Haq and Ahmad Saeed.

Imran Saeed had full knowledge of these transfers, and the belated

application was mala fide.

6. Petitioners also highlighted that Mutations Nos. 293, 294, and 295

dated 13.03.1983 were sanctioned in favour of Mst. Fahmeeda, Seema,

and Lubna regarding sale of land and were never specifically. Hence,

the learned ADCR's order was without jurisdiction, as he was neither

hearing an appeal under Section 161 nor a review under Section 163 of

the Punjab Land Revenue Act, 1967. The order dated 26.10.2021 is

without legal authority. Finally, it was argued that the learned ACR had

passed a well-reasoned order on 29.07.2024.

7. The details of all mutations and general powers of attorney have

already been narrated at length and assessed in the lower courts,

including in the proceedings before the ADCR and the ACR, and are

part of the case record. Therefore, repetition of each transaction is not

necessary at this stage.

8. Addressing the next objection in the impugned order regarding

the validity of General Power of Attorney Nos. 701, 702 dated

13.09.2004, and 4478 dated 25.10.2004, it was clarified that these were

produced before the Member BOR. These powers were executed by

Hamid Saeed, Farukh Saeed, and Hassan Saeed, sons, and Rizwana,

daughter of Ahmad Saeed, concerning residential Ahatta of Mandi

Sadiqabad and land in Mouza Saidpur. The line No. 3 of the GPA

clearly mentioned Saidpur land. GPA No. 702 was executed by Imran

Saeed, son of Mst. Durdana Begum and Shah Jahan Begum, widow of

Zia-ul-Haq, covering the same properties and authorizing transfer

even in favour of relatives. These were registered at Allama Iqbal

Town, Lahore, and verified by Sub-Registrar Sadiqabad (letter dated

29.08.2008) and Sub-Registrar Iqbal Town (letter dated 02.09.2008).

9. It was contended that the General Power of Attorney No. 3136,

Book No. 4, Volume No. 5, Pages 247-248, dated 14.07.1982, remains

intact and has never been challenged. Mutation No. 310 dated

13.03.1984, based on this GPA, pertained to land measuring 634 Kanals

05 Marlas. Since the GPA was registered, only the attorney was

required to appear before the Revenue Officer, not the original

owners.

10. It was further submitted that the ADCR wrongly decided the

matter solely on non-production of the GPA, though certified copies

were submitted. The impugned order was passed in undue haste, on a day the bar was on strike. Moreover, the GPA by Mst. Seema and

Lubna in favour of Ch. Muhammad Anwar authorized alienation in

favour of any person, including family members.

11. The controversial points raised in the application dated

06.07.2010 required evidence and could not be adjudicated summarily

by Revenue Courts. The ADCR's order dated 26.10.2021 mirrors the

written submissions of the respondents and lacks judicial reasoning.

The oral mutation had been implemented in the Jamabandi for forty

years and enjoys presumption of truth under Section 52 of the Punjab

Land Revenue Act, 1967. The Collector lacked jurisdiction to alter such

entries. Reliance was placed on 2020 YLR 1776, 2010 YLR 2687, and

2014 CLC 1484.

12. It was reiterated that under Sections 44, 45, 52, and 53 of the

Punjab Land Revenue Act, 1967, and Section 42 of the Specific Relief

Act, 1877, the jurisdiction of Revenue Officers is limited and

longstanding entries cannot be undone unless so declared by a civil

court.

13. It was emphasized that the respondents never challenged the

General Power of Attorney in any civil court. The petitioners

submitted that no civil court decree was produced by the respondents

regarding Mutations Nos. 2454 and 2459, and the learned Member BOR

misapprehended this point. Under Section 53, any person aggrieved

must approach the civil court; the revenue court has no jurisdiction

over fraud or title disputes.

14. Lastly, it was pointed out that the application dated 06.07.2010

was filed without any substantial legal basis. The learned ACR's order

dated 29.07.2024 had addressed all issues thoroughly. The revision

petition filed by the respondents had no merit, and the impugned

order dated 29.01.2025 is liable to be set aside.

15. The learned counsel for the respondents stated that the

respondents are owners of land measuring 634 Kanals 05 Marlas

situated in Mouza Tulla, Tehsil Sadiqabad, District Rahim Yar Khan,

based on Mutation of Inheritance No. 245 dated 09.03.1976. The

petitioners, being close relatives, were entrusted with managing the

land while the respondents' families resided abroad. It was alleged

that the petitioners got the land transferred through Mutation No. 310

dated 13.03.1984 on the basis of an oral sale, fraudulently sanctioned

by Ch. Muhammad Anwar without any valid Power of Attorney. The

impugned mutation neither referenced nor contained any legitimate

document of authority.

16. Upon discovering this transaction, the respondents filed an

application for correction of the revenue record. The revenue staff submitted a detailed report confirming that the mutations were

sanctioned based on non-existent or irrelevant Powers of Attorney.

Accordingly, the learned Additional Deputy Commissioner (Rev)

accepted the application vide order dated 26.10.2021 and restored

ownership in favour of the respondents. The petitioners' appeal was

transferred to the Additional Commissioner (Rev), Lahore, who, vide

order dated 29.07.2024, erroneously held that the matter be referred to

civil court. Against that order, the respondents filed a revision

petition, which was accepted by this Honourable Court vide order

dated 29.01.2025.

17. The learned counsel submitted that the mutation in question was

sanctioned by Ch. Muhammad Anwar allegedly acting as GPA holder of

Mst. Fahmeeda Begum, but no such document was available on record.

The relied-upon Power of Attorney bearing Document No. 3136 dated

14.07.1982 did not describe any specifie land, Khasra, Khata, or

Khewat numbers, rendering it invalid for the purpose of transfer. He

relied on PLJ 2021 Lahore (Note) 16 (Muzaffar Ali v. Muhammad

Imran) and AIR 1928 Calcutta 385 (Nahar Lai Shah v. Baij Nath Shah) to

argue that a valid Power of Attorney must contain full particulars. He

also cited Unair Ali Khan v. Fait Rasool (PLJ (sic) SC 190), Imam Din v.

Bashir Ahmed (PLJ 2005 SC 418), and Ali Ahmad Akhtar v. Mst. Manna

(2001 SCMR 1700), reiterating that only powers expressly delegated

may be exercised by an agent. He relied on Fida Muhammad v. Pir

Muhammad Khan (1984 SCMR 866) to argue that authority to alienate

property must be explicit. He also cited Section 21 of the Registration

Act, 1908 which mandates full identification of property in any

document affecting immovable property.

18. The learned counsel further submited that neither the alleged

attorney appeared in court voluntarily nor was produced by the

petitioners as a witness, invoking the presumption under Article

129(g) of Qanun-e-Shahadat Order, 1984. Additionally, he reiterated

that insufficient description of property invalidates the GPA, relying

again on AIR 1928 Calcutta 385.

19. He argued that a Power of Attorney must be strictly construed,

with authority traceable within the document's four corners, citing

2004 YLR 288, 2001 SCMR 1700, and 2010 SCMR 1066. Furthermore,

since the land was transferred by the attorney in favour of his

relatives, it was a fiduciary breach. He relied on 2022 SCMR 1068 (Haq

Nawaz v. Banaras) and 2016 SCMR 1781 (Mst. Naila Kausar v. Sardar

Muhammad Bakhsh) to argue that no property transfer by an attorney

to self or relatives is valid without explicit consent of the principal.

20. The legal framework also recognizes that an attorney, acting

under a power of attorney, is bound by fiduciary obligations and cannot transfer property to himself or to his close relatives without the

specific consent of the principal. The superior courts have consistently

reaffirmed this principle in 2022 SCMR 1068 (Haq Nawaz v. Banaras)

and 2016 SCMR 1781 (Mst. Naila Kausar v. Sardar Muhammad Bakhsh),

holding that such actions by attorneys are void unless expressly

authorized. The revenue forums have no authority to presume such

authorization in the absence of specific legal proof and judicial

adjudication.

21. He contended that the mutation was never entered into the

Roznamcha Waqiati, violating Section 42 of the West Pakistan Land

Revenue Act. The absence of such entry vitiates the legal validity of the

mutation and demonstrates a procedural irregularity on the face of the

record.

22. There is also no evidence on file to substantiate the alleged

payment of Rs. 80,000/- as sale consideration recorded in the mutation.

The petitioners have failed to produce any documentary proof, receipt,

or acknowledgment supporting the transaction. This casts serious

doubt on the bona fides of the mutation and reinforces the disputed

nature of the transaction.

23. He stated that the civil suit attached by the petitioners was

irrelevant as it did not concern the property in dispute, which was

transferred through oral mutation. The subject matter of the said suit

pertains to a different parcel of land and has no bearing on the

mutation under challenge. As such, reliance on this civil suit is legally

misplaced and evidentially irrelevant.

24. On the issue of limitation, he submitted that most family

members resided in Lahore and only discovered the fraudulent entries

later. Upon gaining knowledge, the application was filed immediately.

He emphasized that fraud vitiates limitation, citing 2002 SCMR 343

(Haji Hussain v. M.Y. Kherati), where the limitation runs from the date

of knowledge. He added that where fraud is alleged, limitation cannot

defeat a claim. He relied on 2009 CLC 542 and 1983 CLC 156.

25. He argued that Section 53 of the Land Revenue Act does not

apply where the title document is void ab initio. Instead, under Section

172 and Section 45 of the Land Revenue Act, the revenue authorities

have full power to rectify entries based on fraud without requiring

civil court decree. He emphasized that when no complicated question

arises, the Revenue Officers can correct records to avoid unnecessary

litigation. He cited 2007 SCMR 1062 and PLD 2013 Lahore 95 to support

the argument that transfer based on invalid GPA is void ab initio.

26. He responded to the petitioners' challenge to ADCR's jurisdiction

by citing PLJ 1992 Rev. 83/1992 CLC 1600 (Muhammad Ali v. Usman Ghani), affirming that the ADCR, as custodian of record-of-rights, has

review powers and may correct fraudulent entries with permission

from the Commissioner. He explained that the District Collector under

instructions of the Board of Revenue is competent to sanction a

review, and such authority is not excluded merely because a

subordinate officer passed the original order.

27. He concluded that the revision petition was decided through a

speaking order and the instant review fails to meet the criteria under

Section 8 of the Board of Revenue Act, 1957. Thus, it is liable to be

dismissed.

28. Record perused, and arguments have been heard.

29. After reviewing the record, it is evident that the petitioners have

raised a multi-layered factual and legal challenge to the impugned

order dated 29.01.2025. They have demonstrated that the application

leading to the cancellation of Mutation No. 310 was filed after an

inordinate delay of 26 years and was therefore hit by limitation,

supported by PLD 2016 SC 872. The long-standing mutation was based

on a registered General Power of Attorney dated 14.07.1982, which

remains unchallenged.

30. In light of 2020 YLR 1776, 2010 YLR 2687, and 2014 CLC 1484, the

entries carried a presumption of truth under Section 52 of the Punjab

Land Revenue Act, 1967, and the jurisdiction to challenge such entries

rests with the civil courts under Section 53, not Revenue Courts. The

impugned order failed to address this jurisdictional limitation and did

not acknowledge the requirement of instituting a declaratory suit, as

reiterated in Section 42 of the Specific Relief Act.

31. Furthermore, the petitioners substantiated that certified copies

of the GPA were placed before the competent authority and that the

entire claim of the respondents lacks bona fide, as they remained

silent for decades, which is detrimental under 2021 SCMR 1068, 2003

SCMR 1330, and 2020 YLR 666. It is also apparent from the record that

the application was not even signed by the concerned parties and

appears to be a post-facto attempt to challenge valid transactions

concluded long ago.

32. The reasoning provided in the impugned order reflects reliance

on submissions rather than independent judicial evoluation. In such

circumstances, the order of the learned ACR dated 29.07.2024 appears

to be based on sound reasoning and proper appraisal of jurisdictional

33. The mandate of Section 53 of the Punjab Laund Revenue Act,

1967, coupled with authoritative guidance from the superior courts in

PLD 2012 Lahore 160, 2008 SCMR 1658, and 2021 CLC 689, clearly

establishes that the revenue hierarchy acts in execution of civil rights determined by the civil court and cannot function as a parallel

appellate or supervisory body.

34. The legal question that arises is whether a revenue court can

cancel a mutation lawfully entered in the revenue record on the basis

of a registered General Power of Attorney or Oral Transaction, and

construe such mutation as a clerical or factual mistake on the pretext

of alleged fraud. Had the mutation not been based on a legal

document, a different legal scenario might have emerged, even then,

establishing fraud would remain a necessary legal threshold before

any corrective action. It is legally untenable that a mutation rooted in

a legal document has been labeled a mistake merely to circumvent the

procedural rigour of approaching a civil court.

35. Further undermining the respondents' position is the procedural

defect apparent at the outset. The application was filed purportedly on

behalf of individuals who were admittedly deceased, rendering the

proceedings a legal nullity from inception. This defect, coupled with

the complete absence of recourse to a civil court to challenge the legal

documents strips the revenue forum of any jurisdiction. This

conclusion finds reinforcement in 2021 SCMR 391, where it was

categorically held that revenue courts exercise summary jurisdiction

and lack competence to adjudicate questions of fraud, title, or complex

civil rights arising out of civil litigation.

36. From an equitable standpoint, the conduct of the respondents

also triggers the doctrines of acquiescence and estoppel. In 2002 SCMR

1330, 2020 YLR 666, and 2011 SCMR 222, the Hon'ble Supreme Court

consistently held that parties who remain silent for prolonged periods

and fail to challenge transactions in the proper forum, forfeit the right

to belatedly question long-standing revenue entries-especially when

those entries flow from judicial determinations.

37. After careful consideration, it is evident that the powers of

attorney produced by the petitioners were valid, registered, and

covered the land in village Saidpur. The mutation in question was

sanctioned based on these documents, which were duly verified before

the transaction. The learned Member (Judicial-VIII) erred in

overlooking the documentary evidence and instead relied on a

misapprehension of facts. The application of the respondents was not

only delayed beyond the statutory limitation period but also involved

disputed questions of title and allegations of fraud, which fall outside

the jurisdiction of the revenue hierarchy. The superior courts have

consistently held in PLD 1994 SC 336, 2004 SCMR 604, PLD 2020 Lahore

478, and 2014 CLC 1484 that such matters must be resolved by a civil

court. 38. Furthermore, the principle of acquiescence and bar of

limitation, as laid down in 2002 SCMR 1330, 2020 YLR 666, and 2011

SCMR 222, clearly apply. The respondents' silence for over a decade

renders their belated challenge unsustainable. The learned ACR

rightly considered all aspects and passed a well-reasoned order,

while the order dated 26-10-2021 was both procedurally and

substantively flawed.

39. It is settled law that revenue authorities are creatures of statute

and are confined strictly to the jurisdiction vested in them under the

Punjab Land Revenue Act, 1967. They are not courts of plenary

jurisdiction and cannot venture into questions that involve

adjudication of civil rights, title, or allegations of fraud, which require

framing of issues and recording of evidence. As held in PLD 2011 SC

512 and PLD 2010 SC 1, the moment a party alleges fraud or disputes

title based on civil documents, the matter transcends the limited

summary jurisdiction of the revenue forum. The appropriate remedy

lies in a civil sult, where the parties can adduce evidence and obtain a

binding declaration. Permitting revenue officers to cancel or nullify

mutations rooted in registered documents and civil court decrees

would not only amount to exceeding jurisdiction but would render

such instruments legally uncertain, defeating the principles of finality

and sanctity attached to judicial pronouncements and registered acts

under the Registration Act, 1908. It is all the more ironic and legally

untenable that the respondents, despite alleging fraud and having

knowledge of the decree as per their own assertions, knowingly and

deliberately avoided pursuing the appellate and remedial forums

available under the civil law.

40. The scope of review under Section 8 of the Punjab Board of

Revenue Act, 1957, is narrow and exceptional, requiring a

demonstrable error apparent on the face of the record, or a

jurisdictional or legal misapprehension so fundamental as to vitiate

the underlying order. The impugned order dated 29-01-2025, passed by

the same Member (Judicial-VIII), departed from settled legal principles

and disregarded material evidence that had formed the foundation of

the earlier, well-reasoned order dated 29-07-2024. It proceeded on a

misconstruction of both law and fact, failed to engage with the

statutory limitations on revenue jurisdiction under the Punjab Land

Revenue Act, 1967, and overlooked the evidentiary value of registered

documents and civil decrees duly produced on record. This Court,

therefore, is not reappreciating evidence, but correcting a manifest

legal error that strikes at the very root of judicial consistency and

jurisdictional propriety. The review is thus not only maintainable, but

imperative to uphold the integrity of adjudication within the bounds of lawful authority---it was compelled by the imperatives of justice,

legality, and institutional discipline.

41. It is both ironic and perplexing that the respondents never

availed themselves of the remedies available under the law by

instituting any civil or criminal proceedings. No recourse was taken

under the Code of Criminal Procedure, 1898, nor was any action

initiated under the Pakistan Penal Code, 1860.

42. The learned counsel for the respondents has advanced weighty

and well-reasoned arguments pertaining to the alleged commission of

fraud, the inapplicability of limitation in the peculiar circumstances of

the case, and the validity, scope, and competence conferred by the

General Power of Attorney. However, the pivotal issue remains

whether a revenue court is legally vested with the jurisdiction to

adjudicate upon such matters.

43. The respondents rely upon purposive meaning and

interpretation rather than the literal interpretation of Sections 166 and

172(2)(vi) of the Punjab Land Revenue Act, 1967. Section 166 states:

"Clerical or arithmetical mistakes in any decree or order made by any

Revenue Officer, or errors therein from any accidental slip or omission

may, at any time, be corrected by such officer." A literal interpretation

confines this provision strictly to minor, non-substantive corrections

arising from inadvertent slips or computational errors. Even under a

purposive construction, the legislative intent behind this section is to

maintain procedural accuracy-not to confer authority upon revenue

officers to review or annul entries based on civil court decrees.

Likewise, Section 172(2)(vi), which allows "the correction of any entry

in a record-of-rights, periodical record or register of mutations," is

designed for routine administrative corrections. Interpreted

purposively, it does not empower revenue authorities to adjudicate

complex disputes involving title, fraud, or the enforceability of

decrees. Such matters lie exclusively within the jurisdiction of the civil

courts.

44. Therefore, the District Collector is empowered to effect

corrections in the revenue record only where the illegality or

irregularity is manifest, apparent on the face of the record, and

already established through a recognized legal or investigative

process. Where the matter necessitates a detailed appraisal of

evidence for the determination of such questions particularly in

matters involving allegations or commission of fraud, the validity or

competence under a General Power of Attorney, the enforceability of a

decree, the requirement of execution of a decree, or the applicability

of limitation-the jurisdiction of not only the District Collector, but all

revenue courts stand ousted. In such circumstances, revenue courts lack the lawful competence to venture into adjudication of such

complex and inherently civil disputes. Therefore, the respondent has

no lawful grounds to seek relief from the revenue courts in a matter

which squarely falls within the domain of civil adjudication

45. In view of the foregoing, this petition is accepted.

Consequently, the impugned order dated 29-01-2025, passed by the

Member (Judicial-VIII), Board of Revenue, Punjab, is set aside. The

order dated 29-07-2024, passed by the Additional Commissioner

(Revenue), Lahore is upheld, and as a result, the earlier order dated

26-10-2021 passed by the Additional Deputy Commissioner

(Revenue), Rahim Yar Khan, stands set aside. The respondents may

seek appropriate relief before a Civil Court of competent

jurisdiction, if so desired. File be consigned to record room after

completion.

MQ/13/Rev Petition allowed.