Disposed¶6

Kamala Ray v. the State of Jharkhand through Its Chief Secretary

Jharkhand HC7 May 2026WPC/3525/2020

Case brief

AI extract

What is this about?

Mutation dispute; registered gift deed; disputed question of title; property purchased by three brothers; Ghatshila, East Singhbhum, Jharkhand; Kamala Ray v. State of Jharkhand and others (incl. respondent no. 5 Mrs. Kamala Devi); direction to parties to seek adjudication of title in Civil Court; suit to be decided on merits uninfluenced by Revenue authorities' order; Revenue authorities to reconsider mutation after suit decided; writ petition disposed of by Ananda Sen, J. on 07.05.2026.

What did the court decide?

Writ petition disposed of with directions: petitioner and respondent no. 5 to file an appropriate suit in the Civil Court, to be decided on merits without being influenced by the Revenue authorities' order; Revenue authorities thereafter to consider the mutation in terms of this judgment. ¶6

Kamala Ray Vs the State of Jharkhand through Its Chief Secretary — Jharkhand HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the mutation dispute, involving a serious disputed question of title between the petitioner's registered-gift-deed claim and respondent no. 5's contention that the property was purchased by three brothers (one of whom died issueless), should be resolved through the Civil Court rather than at the mutation/revenue stage.

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Court's answer

There is a serious disputed question of title in this case; the gift deed needs to be proved and the title has to be established between the parties.

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Ratio / Principle

The petitioner and respondent no. 5 are directed to approach the Civil Court by filing an appropriate suit, which will be decided on merits without being influenced or prejudiced by the order passed by the Revenue authorities.

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Key takeaways

After the suit is decided, the Revenue authorities will consider the case of the mutation in terms of the judgment passed in this case.ratio¶5

Detailed headnote1 paragraphs

High Court of Jharkhand at Ranchi, W.P (C) No. 3525 of 2020 (decision date 07.05.2026), Ananda Sen, J. — writ petition disposed of. The dispute concerned mutation of property at Ghatshila, East Singhbhum: petitioner Kamala Ray claimed the entire property by virtue of a registered gift deed, while respondent no. 5 (Mrs. Kamala Devi) opposed, contending the property was purchased by three brothers, one of whom died issueless, after which the petitioner got the entire land mutated in her favour leaving out respondent no. 5. Finding a serious disputed question of title — the gift deed needing to be proved and title to be established between the parties — the Court directed the petitioner and respondent no. 5 to approach the Civil Court by filing an appropriate suit, to be decided on merits without being influenced or prejudiced by the order passed by the Revenue authorities; the Revenue authorities were to consider the case of mutation in terms of this judgment after the suit was decided.

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( 2026:JHHC:13698 )

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IN THE HIGH COURT OF JHARKHAND AT RANCHI W.P (C) No. 3525 of 2020

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Kamala Ray, widow of Late Ramnath Ray, resident of Ghatshila, P.O. & P.S.-Ghatshila, District-East Singhbhum.

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… Petitioner(s).

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Versus

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The State of Jharkhand through its Chief Secretary, Project Bhawan, P.O. & P.S.-Dhurwa, District-Ranchi.

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Deputy Commissioner-cum-District Magistrate, East Singhbhum, Jamshedpur, P.O. & P.S.-Sakchi, District-East Singhbhum.

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Land Reforms Deputy Collector, Ghatshila, P.O. & P.S.-Ghatshila, District-East Singhbhum.

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Circle Officer, Ghatshila, P.O. & P.S.-Ghatshila, District-East Singhbhum.

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Mrs. Kamala Devi, wife of Raja Ram Ray, resident of Ghatshila, P.O. & P.S.-Ghatshila, District-East Singhbhum.

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… Respondent(s).

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CORAM :SRI ANANDA SEN, J.

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For the Petitioner(s) : Mr. Ashim Kr. Sahani, Advocate For the respondent(s) : Mr. Kishore Kr. Singh, Advocate

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07/07.05.2026:

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1. Heard the parties.

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2. After going through the record I find that there is dispute in respect of the mutation of the property. The petitioner claims the entire property by virtue of registered gift deed. The respondent no. 5 opposes the same and submits that the property was purchased by three brothers. One brother died issueless and, thereafter, the petitioner brought the entire land mutated in her favour leaving out respondent no. 5.

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3. After hearing the parties, I find that there is a serious disputed question of title in this case. The gift deed needs to be proved and the title has to be established between the parties.

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4. Thus, I direct the petitioner including the respondent no. 5 to approach the Civil Court by filing appropriate suit which will be decided on merits without being influenced and prejudiced by the order passed by Revenue authorities.

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5. The Revenue authorities after the suit is decided will consider the case of the mutation in terms of the judgment passed in this case.

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( 2026:JHHC:13698 )

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6. Accordingly, this writ petition stands disposed of.

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(ANANDA SEN, J.)

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07.05.2026 Rashmi/Uploaded on:-12.05.2026

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