MUHAMMAD ZAIN-UL-ABIDEEN vs HAMID SAEED Ss — 2026 CLC 717 BOARD-OF-REVENUE-PUNJAB

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MUHAMMAD ZAIN-UL-ABIDEEN VS HAMID SAEED Ss.53 & 162---Correction of entries---Factual controversies---Jurisdiction---Civil Court or Revenue Authorities---Limitation---The powers of attorney, in the present case , were valid, registered, and covered the land-in-question; the mutation-in-question was sanctioned based on said documents, which were duly verified before the transaction---Revenue hierarchy erred in overlooking the documentary evidence and instead relied on a misapprehension of facts---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---Such matters must be resolved by a civil court---Furthermore, the principle of acquiescence and bar of limitation were clearly applicable---The respondents' silence for over a decade renders 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 Act, 1967; which 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---Ironically 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---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 had no lawful grounds to seek relief from the revenue courts in a matter which squarely fell within the domain of civil adjudication---Member - Board of Revenue set aside the impugned orders while the order passed by the Assistant Commissioner (Revenue) was upheld ;the respondents might seek appropriate relief before a Civil Court of competent jurisdiction, if so desired---Review petition was allowed.

MUHAMMAD ZAIN-UL-ABIDEEN vs HAMID SAEED Ss — 2026 CLC 717 BOARD-OF-REVENUE-PUNJAB

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