In Brief
The State of Madhya Pradesh appealed a High Court decision reversing the dismissal of a suit filed by a temple deity seeking declaration of ownership and injunction against interference with land records. The temple lands had been continuously recorded in the deity's name until 1979–80, when revenue entries were unilaterally corrected to record the Collector as 'Manager'. The Supreme Court held that this correction violated Section 115 of the Madhya Pradesh Land Revenue Code 1959, which requires written sanction from the Collector, proper enquiry, a Tahsildar's report, and opportunity of hearing to all affected parties for corrections to prior entries. Since proper procedure was never followed, the correction was invalid. The Court dismissed the appeal, affirming that procedural compliance cannot be bypassed for administrative convenience.
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