Revisional authorities exceeded their scope by re-evaluating factual findings without proper evidence.

Facts:

The dispute concerned ownership of land in Deoria, Uttar Pradesh, recorded under Khata Nos. 38 and 193. The appellant, Shambhu Chauhan, claimed sole ownership, while respondent Gulabi claimed co-tenancy as the daughter of a prior owner, Algoo. The Consolidation Officer rejected Gulabi’s claim in 1975, citing lack of evidence. However, higher authorities overturned this, recognizing Gulabi’s rights.

Contentions:
Appellant: The appellate and revisional findings were perverse, unsupported by evidence, and improperly overturned earlier factual conclusions.
Respondent (Gulabi): Asserted her status as Algoo’s daughter and rightful co-tenant but relied on questionable evidence, including an unverified birth register.

Judgment:

The Supreme Court upheld the High Court’s decision, which had restored the original findings of the Consolidation Officer. It held that: Revisional authorities exceeded their scope by re-evaluating factual findings without proper evidence. Gulabi failed to prove her relationship with Algoo and her claim to the land. The long delay in asserting her rights (1959–1973) further weakened her case. The appeal was dismissed, affirming the High Court’s correction of the appellate and revisional errors.

This ruling reinforces the importance of concrete evidence and adherence to procedural limits in property disputes.