Chaudhary MUHAMMAD UMAR vs HAMID SAEED Ss — 2026 CLC 880 BOARD-OF-REVENUE-PUNJAB

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Chaudhary MUHAMMAD UMAR VS HAMID SAEED Ss. 53, 166 & 172(2)(vi)---Transfer through a registered General Power of Attorney---Fraud , plea of---Power of Attorney, challenging of---Jurisdiction---Whether revenue Authorities or civil court?---Held: The transfer-under-challenge was effected through a registered General Power of Attorney and such instrument can only be challenged before a civil court and not by way of administrative proceedings---The powers of attorney produced by the petitioners 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---The application of the respondents involved disputed questions of title and allegations of fraud, which fell outside the jurisdiction of the revenue hierarchy and such matters must be resolved by a civil court---Revenue authorities are courts of plenary jurisdiction and cannot venture into questions that involves adjudication of civil rights, title or allegations of fraud, which requires framing of issues and recording of evidence---Section 166 of the Punjab Land Revenue Act, 1967 confines to minor, non-substantive corrections arising from inadvertent slips or computational errors while S.172(2)(vi) of the Punjab Land Revenue Act, 1967 is designed for routine administrative corrections and 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---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 is already established through a recognized legal or investigative process---Thus, the impugned 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.

Chaudhary MUHAMMAD UMAR vs HAMID SAEED Ss — 2026 CLC 880 BOARD-OF-REVENUE-PUNJAB

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