In Brief
A tribal person (Respondent No.1) purchased tribal-owned land in 1981 and sued for a declaration of title. Revenue authorities had earlier declared the transaction benami (fictitious) and void. The Supreme Court upheld the trial and appellate courts' dismissal of the defendants' appeal, holding that civil courts can independently enquire into such transactions. Since both buyer and seller were tribal, the question of whether the purchase was genuine involves factual matters—like actual possession and beneficial occupation—that civil courts can properly examine. Revenue authorities' earlier findings do not bind the civil court and do not bar its jurisdiction under land revenue law.
The lawyer headnote and full judgment text are available to registered users.