In Brief
A private company holding title to agricultural land through sale deeds filed a civil suit seeking cancellation of a subsequent sale deed executed by the same seller (alleging fraud) and injunction against the defendants. The defendant challenged maintainability under Section 331 of the U.P. Zamindari Abolition and Land Reforms Act, 1950, which generally restricts civil court jurisdiction over agricultural land disputes. The Supreme Court held that where a recorded tenure holder has prima facie valid title and seeks cancellation of a fraudulent deed without claiming any new declaration of title, the civil suit is maintainable. Revenue Courts lack jurisdiction to cancel deeds on fraud grounds. Both appeals were dismissed."
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