Sri B.R. Srinivas Vs State of Karnataka — Writ and Judicial Review | Karnataka HC (2026)

Sri B.R. Srinivas Vs State of Karnataka — Writ and Judicial Review | Karnataka HC (2026)

What the court decided

AI extract

Outcome

Mandamus issued: respondent No.3 directed to enter the petitioner's name in the revenue records in respect of 1 acre 30.5 guntas (excluding the disputed 6 guntas) as per the certificate of sale dated 23.03.2009 (Annexure B), within 2 months of receipt of a copy of the order; respondent-authorities left free to conduct phodi and durasth at the earliest.

Issue for consideration

Whether the petitioner, who holds a Form No.41 Certificate of Sale of Immovable Property dated 23.03.2009 (Annexure-B), is entitled to a mandamus directing entry of his name in the revenue records for the scheduled land. +1 more

Court's answer

Following the law declared by the Hon'ble Supreme Court in Kavitha Vs. Dhanalakshmi, a certificate of sale of immovable property issued by the competent authority is equivalent to a registered sale, and therefore the petitioner shall be considered as the owner of the land in question.

Ratio / Principle

Respondent No.3 is directed to enter the petitioner's name in the revenue records for the subject land scheduled in the certificate of sale of immovable property dated 23.03.2009 (Annexure B), within a period of 2 months from receipt of a copy of the order.

Key takeaways

As the total extent is 1 acre 36.5 guntas and there is a dispute with regard to 6 guntas, the respondent-authorities are to enter the petitioner's name in the revenue records in respect of 1 acre 30.5 guntas.ratio¶32

Detailed headnote1 paragraphs

Writ petition under Articles 226 and 227 of the Constitution of India seeking mandamus to consider representations dated 10.04.2026 (Annexures K to K3) for entry of the petitioner's name in revenue records. The Court, following the declaration of law by the Hon'ble Supreme Court in Kavitha Vs. Dhanalakshmi (footnoted as SLP(Civil)No.5987/2018), held that a certificate of sale of immovable property (Form No.41, dated 23.03.2009, Annexure-B) issued by the competent authority is equivalent to a registered sale; consequently the petitioner was to be considered owner of the scheduled land. Respondent No.3 was directed to enter the petitioner's name in the revenue records for 1 acre 30.5 guntas (excluding 6 guntas under dispute out of a total extent of 1 acre 36.5 guntas) within 2 months of receipt of a copy of the order, and the respondent-authorities were left free to conduct phodi and durasth at the earliest. Petition disposed of.

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NC: 2026:KHC:35316 WP No. 18594 of 2026

HC-KAR

IN THE HIGH COURT OF KARNATAKA AT BENGALURU

DATED THIS THE 10^TH DAY OF JULY, 2026

BEFORE

THE HON'BLE MR. JUSTICE E.S.INDIRESH WRIT PETITION NO. 18594 OF 2026 (KLR-RES)

BETWEEN:

SRI B.R. SRINIVAS S/O LATE RAMAIAH B AGED ABOUT 67 YEARS R/AT FLAT NO.410, MANGAM ELITE APARTMENT 2^ND SECTOR, HSR LAYOUT BENGALURU - 560 102

…PETITIONER

(BY SRI. PRASANNA KUMAR S..,ADVOCATE) AND:

Digitally signed by CHAYA S A Location: HIGH COURT OF KARNATAKA

STATE OF KARNATAKA REVENUE DEPARTMENT VIKASA SOUDHA DR. AMBEDKAR ROAD BENGALURU - 560 001 REPRESENTED BY ITS SECRETARY

DEPUTY COMMISSIONER BENGALURU URBAN DISTRICT K.G. ROAD, BENGALURU - 560 009

DEPUTY COMMISSIONER (ENFORCEMENT CELL) K.G.ROAD, BENGALURU DISTRICT-09

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NC: 2026:KHC:35316 WP No. 18594 of 2026

HC-KAR

ASSISTANT DIRECTOR OF LAND RECORDS ANEKAL TALUK, ANEKAL - 562 106

…RESPONDENTS

(BY SMT. SHARADA H.V., AGA)

THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE MANDAMUS DIRECTING RESPONDENTS TO CONSIDER AND DISPOSE REPRESENTATIONS DATED10.04.2026 HEREWITH PRODUCED AS ANNEXURE-K TO K-3 AND ETC.

THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE E.S.INDIRESH

ORAL ORDER

In this writ petition, petitioner has sought for writ in the nature of mandamus to consider the representation dated 10.04.2026 (Annexures K to K3), inter alia sought for direction to respondent No.2 to enter the name of the petitioner in the revenue records.

Having heard the learned counsel appearing for the parties, respondent No.2 has issued the Form No.41 as Certificate of Sale of Immovable Property dated 23.03.2009 (Annexure-B).

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NC: 2026:KHC:35316 WP No. 18594 of 2026

HC-KAR

In that view of the matter, following the declaration

of law made by the Hon'ble Supreme Court in the case of Kavitha Vs. Dhanalakshmi¹ , if the certificate of sale of immovable property is issued by the competent authority and same shall be equivalent to the registered sale and therefore, I am of the opinion that, the petitioner shall be considered as the owner of the land in question and accordingly, respondent No.3 is directed to enter the name of the petitioner in the revenue records pertaining to the subject land in the schedule mentioned in the certificate of sale of immovable property dated 23.03.2009 (Annexure B) within a period of 2 months from the date of receipt of copy of this Order.

In that view of the matter, as the total extent of land is 1 acre 36 and half guntas, however, leaving 6 guntas of land from the aforementioned extent of land since there is a dispute with regard to 6 guntas, the respondent - authorities are directed to enter the name of the petitioner in respect of 1 acre 30.5 guntas in the Revenue records.

1 SLP(Civil)No.5987/2018

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NC: 2026:KHC:35316 WP No. 18594 of 2026

HC-KAR

It is also open for the respondent - authorities to

conduct phodi and durasth in respect of the land in question at the earliest.

With this observation, petition is disposed of .

SD/(E.S.INDIRESH) JUDGE

BH/SAC List No.: 1 Sl No.: 53