From Tehsil To The Apex Court: Mutation On Will Re-validated

On 19 December 2025 a two-Judge Bench of the Supreme Court of India (Manoj Misra & Sanjay Karol, JJ.) allowed Civil Appeal No. 15077 of 2025 arising out of SLP(C) No. 22439 of 2024 and, by a single stroke, restored a mutation entry recorded in favour of the appellant while simultaneously clarifying the interface between summary revenue proceedings and the adjudicatory monopoly of civil courts. Tarachandra v. Bhawarlal & Anr. is the latest reiteration that a registered will is a legitimate foundation for mutation under the Madhya Pradesh Land Revenue Code, 1959 and the Madhya Pradesh Bhu-Rajasv Sanhita (Bhu-Abhilekhon Mein Namantaran) Niyam, 2018; that an objection founded on an unregistered agreement to sell and pleas of adverse possession cannot interdict such mutation when no legal heir contests the testament; and that the supervisory jurisdiction under Article 227 cannot be invoked to annul an administrative order that suffers neither jurisdictional error nor legal