VidhiSangh

Supreme Court of India · 01/05/2024

RAM BALAK SINGH versus STATE OF BIHAR AND ANR.

[2024] 6 S.C.R. 1 · 2024 INSC 360

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Summary

A final consolidation adjudication recognising title could not be ignored or reversed by the civil appellate courts. Unlike ordinary revenue entries, the order resulted from a competent determination of rights and had never been challenged by the State. Section 37 barred suits attacking consolidation decisions, but not this later suit seeking recognition of the rights already adjudicated after fresh interference. The trial court’s declaration and possession decree was restored.

Issues

  1. Whether final adjudication by the consolidation authority could be disregarded by a civil court.
  2. Whether Section 37 barred a suit recognising rather than challenging that adjudicated right.

Provisions considered

Held

Result

Appeal allowed; adverse appellate judgments set aside and trial court decree restored. No costs.

Judgment PDF: Supreme Court of India, [2024] 6 S.C.R. 1.