Pranadhar Agrawal v. State of Chhattisgarh

Chhattisgarh HC19 Jul 2026WPC/724/2023

Case brief

AI extract

What is this about?

Mutation cancellation by Tahsildar; subsequent purchaser during pendency of civil suit; lis pendens; subsequent purchaser steps into the shoes of the seller or original contesting party; no independent right to seek mutation; Revenue Revision Case No. RN/23/R/A6/324/2017; Revenue Appeal No. 655/A-6/2013-14; Chhattisgarh Board of Revenue Circuit Court Raipur; S.D.O.; Additional Commissioner; condonation of delay; decree final up to High Court; Smt. Triveni Bai; WPC No. 724 of 2023; Chhattisgarh High Court Bilaspur.

What did the court decide?

No substantive relief; the petition was disposed of with the observation that the petitioners may assail the orders passed by the concerned Civil Court before the appropriate authority in accordance with law. ¶¶56

Pranadhar Agrawal Vs State of Chhattisgarh — Chhattisgarh HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the petitioners, who purchased the property during the pendency of proceedings, have an independent right to seek mutation of the property. +1 more

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Court's answer

It is a settled position of law that where a property is purchased during the pendency of proceedings, the subsequent purchaser steps into the shoes of the seller or the original contesting party from whom the property has been purchased.

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Ratio / Principle

The petitioners, being subsequent purchasers whose seller had contested the matter before every forum, do not have any independent right to seek mutation of the property.

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Key takeaways

The petitioners are at liberty to assail the orders passed by the concerned Civil Court before the appropriate authority in accordance with law.ratio¶¶55

Detailed headnote1 paragraphs

HIGH COURT OF CHHATTISGARH AT BILASPUR (WPC No. 724 of 2023, Hon'ble Mr. Justice Amitendra Kishore Prasad, order dated 20/07/2026): Purchasers sought to set aside the Board of Revenue revision order dated 21.10.2022 (Revenue Revision Case No. RN/23/R/A6/324/2017), condonation of delay in filing an appeal before respondent No. 3, and a direction to decide Revenue Appeal No. 655/A-6/2013-14, after their mutation entries were cancelled by the Tahsildar pursuant to a Civil Court decree. The Court noted the seller had contested every forum and the decree had attained finality up to the High Court in favour of respondent No. 4, Smt. Triveni Bai, and that the petitioners had purchased on 02.07.1996 during the pendency of the 1995 civil suit. Held: a purchaser during the pendency of proceedings steps into the shoes of the seller or original contesting party and has no independent right to seek mutation. Petition disposed of with liberty to assail the Civil Court orders before the appropriate authority.

CGHC010047382023

2026:CGHC:30670

NAFR

HIGH COURT OF CHHATTISGARH AT BILASPUR

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WPC No. 724 of 2023

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1 - Pranadhar Agrawal S/o - Late Shri Atmanand Agrawal, aged about 69 years R/o - Agrawalpara Arang, Police Station and Tahsil - Arang, District - Raipur, Chhattisgarh, Mob. No. - 9893832033.

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Digitally signed by RAVVA UTTEJ KUMAR RAJU

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2 - Ayush Agrawal S/o Shri Pranadhar Agrawal Aged About 24 Years R/o - Agrawalpara Arang, Police Station And Tahsil - Arang, District - Raipur, Chhattisgarh, Mob. No. - 9893832033

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... Petitioners

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Versus

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1 - State of Chhattisgarh Through - Secretary Department Of Revenue, Mahanadi Bhawan, New Mantralaya, Atal Nagar, Naya Raipur, District : Raipur, Chhattisgarh.

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2 - Chhattisgarh Board Of Revenue Circuit Court Raipur, District : Raipur, Chhattisgarh.

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3 - Additional Commissioner Durg Division Durg, Chhattisgarh..

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4 - Smt. Triveni Bai (Died And Deleted) As Per Hon'ble Court Order Dated On 06-07-2026.

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5 - Arun Dutta Dubey S/o Late Shri Ramgopal Dubey Aged About 56 Years

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R/o Village Nawagarh, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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6 - Suresh Dutta Dubey S/o Late Shri Ramgopal Dubey Aged About 59 Years R/o Village Nawagarh, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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7 - Smt. Sangeeta Dubey W/o Late Shri Ramesh Dutta Dubey Aged About 50 Years R/o Village Nawagarh, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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8 - Rahul Dubey S/o Late Ramesh Dutta Dubey Aged About 23 Years R/o Village Nawagarh, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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9 - Ku. Aditi Dubey D/o - Late Ramesh Dutta Dubey Aged About 27 Years R/o Village Nawagarh, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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10 - Ku. Rani Dubey D/o - Late Ramesh Dutta Dubey Aged About 25 Years R/o Village Nawagarh, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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11 - Dinesh Dutta S/o Late Shri Ramgopal Dubey Aged About 51 Years R/o Village Nawagarh, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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12 - Smt. Aupa Bai Pandey D/o Late Ramgopal Dubey, W/o - Shri Bhaskar Pandey, Aged About 63 Years R/o Village - Kawardha, Police Station, Tahsil And District - Kawardha, Chhattisgarh.

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13 - Smt. Urmila Dubey W/o - Late Shri Chandra Dutta Dubey Aged About 67 Years R/o Village Nawagaonkala, Post - Tipdi, Tahsil - Khamhariya, District : Bemetara, Chhattisgarh.

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14 - Rakesh Dubey S/o Late Shri Chandra Dutta Dubey Aged About 45 Years

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R/o Village Nawagaonkala, Post - Tipdi, Tahsil - Khamhariya, District : Bemetara, Chhattisgarh.

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15 - Smt. Manjusha Tiwari D/o Chandra Dutta Dubey, W/o Shri Bharat Prasad Tiwari, Aged About 40 Years R/o Village Nawagaonkala, Post - Tipdi, Tahsil - Khamhariya, District : Bemetara, Chhattisgarh.

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16 - Smt. Ranu Mishra D/o Late Chandra Dutta Dubey, W/o Dhananjay Mishra Aged About 37 Years R/o Panchsheel Nagar, Durg, Police Station, Tahsil And District - Durg, Chhattisgarh.

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17 - Smt. Sunita Bai Dubey W/o Late Shri Anil Dutta Dubey Aged About 45 Years R/o - Village Khamhi, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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18 - Harsh Dutta Dubey S/o Late Shri Anil Dutta Dubey Through Next Firend Mother Smt. Sunita Bai Dubey, Aged About 45 Years W/o - Late Shri Anil Dutta Dubey, R/o - Village Khamhi, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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19 - Sunil Dutta Dubey S/o Late Shri Shankardutt Dubey, Aged About 45 Years R/o Village Khamhi, Police Station And Tahsil - Nawagarh, District : Bemetara, Chhattisgarh.

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... Respondents

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(Cause title is taken from CIS Periphery.)

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For Petitioners : Mr. Ratnesh Kumar Agrawal, Advocate. For State : Mr. Soumitra Kesharwani, P.L. For Respondents No. 6 to 12 : Mr. Nimesh Kumar Jha, Advocate along with Mr. Anand Kesharwani, Advocate.

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Hon’ble Mr. Justice Amitendra Kishore Prasad

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Order on Board

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20/07/2026

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The petitioners have filed the instant petition for following reliefs:-

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“10.1 That, this Hon’ble Court may kindly be

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pleased to call for entire records of the case, from the authorities.

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10.2 That, this Hon’ble Court may kindly be pleased to set-aside the impugned order dated 21.10.2022 passed by respondent No. 2 in Revenue Revision Case No. RN/23/R/A6/324/2017 between “Pranadhar Agrawal & other Vs. Smt. Triveni Bai & others” (Annexure-P/1) and further be please to condone the delay in filing the appeal preferred by petitioners before respondent No. 3, is in the interest of justice.

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10.3 That, this Hon’ble Court may kindly be pleased to direct to the respondent No. 3 to decide the Revenue Appeal No. 655/A-6/2013-14 on its own merit, is in the interest of justice.

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10.4 That, this Hon’ble Court may kindly be pleased to grant any other relief(s), which is deemed fit and proper in the aforesaid facts & circumstances of the case.”

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Learned counsel appearing for the petitioners submits that the mutation entries in favour of the petitioners were cancelled by the concerned Tahsildar on the basis of the judgment and decree passed by the Civil Court without affording any opportunity of hearing to the petitioners. It is submitted that thereafter, the seller from whom the petitioners had purchased the property preferred an appeal before the S.D.O.; however, the same was dismissed holding that appropriate orders had already been passed. Subsequently, the concerned Commissioner also passed an order against the petitioners, in which they were parties. Thereafter, the petitioners preferred a revision petition before the concerned Commissioner, who affirmed the orders passed by the S.D.O. and the Tahsildar, leading to the filing of the present petition. He also submits that the petitioners were not granted an opportunity of hearing before the Tahsildar and, therefore, the orders passed are not in accordance with law. However, he could not dispute the fact that the seller from whom the petitioners had purchased the property had

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contested the proceedings. He further submits that the rights of the seller have already been determined in the civil suit and the claim for half share of the property has been declined in favour of the petitioners, which aspect has not been considered.

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Learned counsel for respondents No. 6 to 12 submits that the dispute has already been adjudicated by the Civil Court and the decree has attained finality up to the High Court in favour of respondent No. 4-Smt. Triveni Bai. It is submitted that the said order was well within the knowledge of the seller from whom the petitioners had purchased the property, and therefore, he challenged the same up to the High Court. It is further submitted that the petitioners purchased the property on 02.07.1996 during the pendency of the civil suit, which was instituted in the year 1995, and thus, they have stepped into the shoes of the original owner from whom they derived their title. Since the original owners had participated in all the proceedings and contested the matter each and every time, the orders passed therein would be binding upon the petitioners as well.

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Learned State counsel submits that the orders passed by the authorities concerned are just and proper and do not call for any interference.

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Having heard learned counsel for the parties and upon perusal of the record, it appears that the seller from whom the petitioners have purchased the property had contested the matter before every forum and, after failing therein, the petitioners have approached the authorities seeking mutation of the property. It is a settled position of law that where a property is purchased during the pendency of

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proceedings, the subsequent purchaser steps into the shoes of the seller or the original contesting party from whom the property has been purchased. Therefore, in the opinion of this Court, the petitioners do not have any independent right to seek mutation of the property. However, the petitioners shall be at liberty to assail the orders passed by the concerned Civil Court before the appropriate authority in accordance with law.

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With this observation and direction, the petition stands disposed of.

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Sd/-

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(Amitendra Kishore Prasad)

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Judge

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U.K. Raju

Pranadhar Agrawal v. State of Chhattisgarh

Case brief

What is this about?

What did the court decide?

Pranadhar Agrawal v. State of Chhattisgarh

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Procedural history

Parties & counsel

Coram

Case details

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