Why Your Temple’s Name in Land Records May Not Protect Its Property, Supreme Court's judgment explained

The Supreme Court has reiterated that entries in revenue records, even if they reflect long-standing possession or payment of land revenue, cannot by themselves establish ownership of property. The ruling has significant implications for temples, mutts and other religious institutions that rely primarily on revenue documents to assert control over land.

The observation was made while dismissing a civil appeal filed by Panchavatige Mutt, Togarsi, which had sought declaration of title and permanent injunction in respect of agricultural land situated in Karnataka. A Bench of Justices Sanjay Karol and Satish Chandra Sharma upheld concurrent findings of the Trial Court and the Karnataka High Court, both of which had rejected the mutt’s claim for failure to prove legal ownership.

The dispute related to land measuring 15 acres and 14 guntas located at Togarsi village in Shikaripura Taluk. The mutt approached the civil court contending that it was the rightful owner of the land and that its possession was evidenced by entries in the revenue records, which reflected the name of its administrator. It was also asserted that land revenue and associated taxes had been paid regularly over the years.

However, the Civil Judge (Senior Division), Sagar, by a judgment dated February 20, 2007, dismissed the suit after concluding that the plaintiff had failed to establish either title or lawful possession over the suit schedule property. The Trial Court held that revenue records, which are maintained for fiscal purposes, do not confer ownership and cannot substitute for proof of title.

The mutt challenged this decision before the Karnataka High Court through a Regular First Appeal. By its judgment dated November 15, 2010, the High Court affirmed the Trial Court’s findings, reiterating that mere mutation entries or payment of land revenue cannot establish ownership rights. The High Court also declined to interfere with the Trial Court’s assessment of possession.

Undeterred, the mutt approached the Supreme Court, once again relying on the revenue entries to support its claim. The apex court, however, found no merit in the appeal.

“It is apparent from the record that the claim of the appellant is sourced only from entry in the revenue records. There can be no dispute that the same cannot form the basis of the claim over title of any property,” the Bench observed.

The Court noted that this legal position is well settled and has been consistently reiterated in earlier decisions. It cited judgments in Balwant Singh v. Daulat Singh (1997), Suraj Bhan v. Financial Commissioner (2007), and Bhimabai Mahadeo Kambekar v. Arthur Import & Export Co. (2019), all of which held that revenue records may indicate possession or cultivation but do not, by themselves, confer ownership.

The Supreme Court also took note of the fact that a court-appointed commissioner had submitted a report indicating possession in favour of the mutt. However, it observed that both the Trial Court and the High Court had declined to accept this as sufficient proof to establish title, and no error was found in their reasoning.

The judgment underscores an important principle with wider relevance, particularly for religious institutions that manage land over long periods without formal title documents. Across the country, many temples and mutts rely on historical possession, oral grants or revenue entries to assert control over property. The Supreme Court’s ruling reiterates that such factors, while relevant for administrative purposes, do not meet the legal threshold required to establish ownership.

At the same time, the Court did not hold that religious institutions cannot own land or that their claims are inherently invalid. The ruling merely clarifies that claims of title must be supported by legally admissible documents such as grants, title deeds or lawful transfers, regardless of whether the claimant is a private individual, a trust or a religious institution.

Finding no legal infirmity in the judgments of the lower courts, the Supreme Court dismissed the civil appeal and declined to interfere with the concurrent findings.

Case Title: Panchavatige Mutt, Togarsi v. Gram Panchayathi Togarsi

Bench: Justice Sanjay Karol and Justice Satish Chandra Sharma

Date of Judgment: January 15, 2026