2026 PLP 880 (CLC)

RASHAD AHMAD KHAN, MEMBER (JUDICIAL-VIII)

This Revision Petition No.47/ 2025 in ROR No. 2008/2024, has been filed under Section 8 of the Punjab Board of Revenue Act, 1957, against the impugned order dated 29-01-2025, passed by the learned Member (Judicial-VIII), Board of Revenue, Punjab, whereby the order dated 29-07-2024, passed by the learned Additional Commissioner Revenue, Lahore, was set aside.

2. Brief facts of the case are that the respondents filed an application dated 06-07-2010 through special attorney Imran Saeed before Deputy Commissioner, Rahim Yar Khan, for correction of revenue record and cancellation of Mutation No. 586 dated 30-09-1999 that was on the basis of decree of Civil Judge dated 27.07.1992. The learned ADCR (Additional Deputy Commissioner, Revenue, Rahim Yar Khan) accepted the application of respondents vide order dated 26.10.2021. The present petitioners filed an appeal against the order dated 26-10-2021 before the ACR (Additional Commissioner, Revenue, Lahore), which was accepted vide order dated 29-07-2024. That the respondents filed Revision Petition No. 2008/2024 against the above said order, which was accepted by the learned Member (Judicial-VIII), Board of Revenue, Punjab, vide order dated 29-01-2025. Hence, this review petition.

3. The learned counsel for the petitioners stated that the impugned order has been passed against the law and facts as an error apparent on the face of the file while important record has been misread and overlooked. It was contended that the impugned mutation was attested on the basis of a civil court decree, and in such circumstances, the jurisdiction of the revenue courts should have been curtailed. It was argued that the application dated 06.07.2010 had been filed after a period of more than 16 years from the sanctioning of Mutation No. 586 dated 30-09-1999, and therefore was barred by limitation. This point, however, was not discussed by the learned Member (Judicial-VIII), which alone warranted review.

4. The impugned order has been passed against the law and facts, containing an apparent error on the face of the file, as important records were misread and overlooked. The factual controversy was not addressed by the court, and the jurisdiction of the revenue court was not considered in the context of the civil court decree on which the mutations were based. The respondents filed their application for cancellation of Mutation No. 586 dated 30-09-1999 after a delay of more than 16 years. The application is barred by limitation, but this was not discussed in the impugned order, and this fact was grossly overlooked in the impugned order.

5. It was submitted that the observation in the impugned order-that the petitioners had failed to produce certified copies of the civil court decree-was incorrect. Certified copies were part of the revision petition file. Therefore, the order is based on a misconception of fact. The learned MBR wrongly stated that the petitioners did not submit certified copies of the judgment and decree, when in fact they had been duly submitted and were part of the original file. The impugned order was based on this misconception of facts. The respondents filed the application against a deceased person (Mst. Jameela Begum), making the application not maintainable. The learned ADCR and MBR did not discuss this crucial fact in their orders, rendering the impugned order liable to be set aside.

6. The learned counsel for the petitioner submitted further arguments in support of this review petition against the impugned order dated 29-01-2025 passed by the learned Member (Judicial-VIII), Board of Revenue, Punjab. It was contended that the impugned order had erroneously recorded that the petitioners failed to produce the original civil court decree, the execution petition, and a report of the record keeper indicating non-existence of the relevant documents. In fact, the respondents themselves had submitted a report stating that the record was not traceable, and the petitioners merely requested time to locate and produce the necessary documents. That process has now been completed, and certified copies of the decree, as well as newly issued certified copies, have been submitted before this Court. Thus, the core objection regarding the non-availability of the decree, as raised in the impugned order, stands duly addressed and cured.

7. It was further argued that the respondents never disputed the existence of the decree; their only contention was that the execution petition was allegedly non-existent and that the decree had been implemented directly in the revenue record. In this regard, the counsel submitted that the existence of the decree should not be in question now, and certified copies thereof are now available for perusal by the Court and the learned counsel for the respondents. With respect to the second objection mentioned in the impugned order-relating to non-execution of the decree-the learned counsel submitted that the necessity of execution arises only where balance consideration remains unpaid between the vendor and the vendee. Relying upon a judgment authored by Honourable Mr. Justice Ahmad Nadeem Ashraf, it was contended that when there is no outstanding balance and possession is already with the vendee, there is no requirement to initiate execution proceedings. The decree in question arose out of mutual agreement, possession had already been transferred to the petitioners, and thus, execution was not necessary. Hence, the two major legal objections recorded in the impugned order-non-availability of the decree and lack of execution-stand answered both factually and legally.

8. Addressing the next objection in the impugned order regarding the validity of General Power of Attorney No. 4479 dated 25-10-1994, the learned counsel argued that objections raised about the agent executing a gift in favour of close relatives are misconceived. The General Power of Attorney in question included general and inclusive language covering the entire village, which is consistent with prevalent practice in 1994. It was not required to mention khasra or khewat numbers specifically, as the authority to alienate property was already vested. Furthermore, the document specifically authorized the donee to transfer the property, including to blood relatives. It was emphasized that under law, the detail of the property is not required in a general power of attorney at the time of execution−only at the time of alienation. The respondents never challenged or cancelled the power of attorney before any forum. Certified copies of the said instrument have now been produced, and it was reiterated that registration in Lahore was consistent with the residence of both parties at that time. Thus, objections regarding scope, form, or registration of the power of attorney are legally untenable.

9. Turning to the issue of alleged fraud, the learned counsel submitted that the Additional Commissioner Revenue, Lahore, did not erroneously refer the matter to the civil court; rather, it is the respondents themselves who alleged fraud and are now under legal obligation to substantiate that allegation in the appropriate forum. The law is clear: only a civil court has jurisdiction to adjudicate allegations of fraud after framing of issues and recording of evidence. As such, the burden lies upon the respondents to approach the civil court and prove their claim. Revenue courts have no jurisdiction to make findings of fraud or cancel lawful mutations on such basis. Therefore, entries in the revenue record must be maintained as they are until a civil court declares otherwise. The learned counsel stressed that this is not a case of mere correction of the revenue record under Section 172 of the Punjab Land Revenue Act, 1967. Rather, the dispute relates to cancellation of a mutation, a mutation that was entered into revenue record on the basis of a valid civil court decree and registered general power of attorney. The respondents never identified any clerical or factual error in the revenue entries before the District Collector or this Court. It is therefore wholly misplaced and legally flawed to treat a properly sanctioned mutation-rooted in civil adjudication-as a mistake in the revenue record. The matter falls squarely within the purview of Section 53 of the Punjab Land Revenue Act, 1967, under which a person aggrieved from entries in the revenue record must approach the civil court for declaratory relief. The respondents, instead of pursuing the correct legal course, attempted to reframe a civil dispute as a case of administrative correction.

10. In counter argument to the argument of the learned counsel for the respondent in which he stated that fraud nullifies limitation, the learned counsel for the petitioner asserted that even in cases involving allegations of fraud, the existence of fraud must first be proved, and even limitation applies in fraud as well. In the present case, the impugned mutations were sanctioned under Section 42 of the Punjab Land Revenue Act on the basis of validly executed general powers of attorney. If the respondents were aggrieved by the contents or execution of those documents, the proper legal recourse was to challenge the same before a civil court, which they never did. Furthermore, two of the impugned mutations were sanctioned on the basis of the civil court decree, and two were on the basis of general power of attorney. If the respondents now allege that such decree was not executed or was fraudulently obtained, their remedy lies in initiating proceedings under Section 12(2), C.P.C. The learned counsel submitted certified copies of the civil court decree before the court and counsel for the respondent. The respondents' failure to pursue the appropriate civil remedies renders their objections unsustainable.

11. Mutation No. 586 was sanctioned based on a civil court decree dated 27-07-1992, and revenue officers are duty-bound to implement such decrees in the revenue record. The MBR failed to address this legal point, which is a ground for reviewing the impugned order. Reliance is placed on judgments such as 2021 CLC 689, PLD 2012 Lahore 160, and 2008 SCMR 1658. Superior courts have ruled that when mutations are sanctioned based on a civil court decree, the proper forum to challenge them is the civil court, not the revenue authorities. The MBR did not discuss this principle, which justifies the review of the impugned order. Relevant cases include 2008 SCMR 1658, 2013 SCMR 906, 2019 YLR 710 and 2021 SCMR 391.

12. The petitioners are bona fide purchasers of the suit land through a registered General Power of Attorney. As per various judgments, such disputed entries can only be corrected through a decree of the competent court, not by revenue officers. This point was not considered by the MBR in the impugned order. There are long-standing entries in favor of the petitioners, and such cases are not maintainable in revenue courts. If the respondents have any grievances, they should approach the civil court. Relevant case: 2014 CLC 1484.

13. The principle of acquiescence applies in this case because the original owners and respondents remained silent and did not challenge the entries, which have attained finality. The respondents have no right to challenge the same. Reliance is placed on 2002 SCMR 1330, 2020 YLR 666, and 2011 SCMR

222. The issues raised in the respondents' application dated 06.07.2010 required evidence and could not have been decided without it. Revenue courts lack jurisdiction to resolve such contradictory issues, and the application should have been dismissed at the initial stage. The application dated 06.07.2010 was filed for correction of revenue records without challenging any mutation. The ADCR's order dated 26.10.2021 was passed without jurisdiction, as he was neither hearing an appeal nor a review petition. Therefore, it should have been addressed by the civil court. The learned ACR passed a well-reasoned order, which should be upheld. Section 53 of the Land Revenue Act, 1967 applies to this case, allowing a suit for declaration if someone considers themselves aggrieved by an entry in the record of rights. The respondents' application does not meet these criteria.

14. The respondents' application was styled under Sections 166 and 172 for "correction," not cancellation, making it not maintainable. The petitioners are bona fide purchasers as they hold valid title via registered General Power of Attorney (GPA), which is still effective, Cited cases: PLD 1994 SC 336, 2004 SCMR 604, PLD 2020 Lahore

478. The mutation is 25 years old. Entries that old cannot be disturbed via summary revenue proceedings. Cited case: 2014 CLC 1484.

15. The decree passed in favor of the petitioners has attained finality, and the respondents never challenged it. Therefore, the order of the learned ACR is well-reasoned and should be upheld. The respondents' application was filed under Sections 166 and 172 of the Land Revenue Act, 1967, for correction of an inadvertent error, but they did not seek the cancellation of the mutation. The learned ACR rightly dismissed the application, but the MBR wrongly set aside the order, which is another reason to review the impugned decision, and requested for the acceptance of the petition.

16. The learned counsel for the respondents submitted that the petitioners had managed the land of the respondents, who are close relatives, as the respondents resided in Lahore. It was stated that land measuring 240 Kanals 7 Marlas was transferred through gift Mutations Nos. 540 and 541 dated 25.10.1997 on the basis of a non-existent Power of Attorney No. 4479 dated 25.10.1994, while land measuring 542 Kanals was transferred through Mutation No. 586 dated 30.07.1996 on the basis of a judgment and decree dated 27.07.1992 allegedly passed by the Civil Judge, Sadiqabad.

17. The counsel submitted that upon discovering these transactions, the respondents filed applications for correction of the revenue record. Reports from field staff confirmed that the impugned mutations were sanctioned on the basis of either non-existent or irrelevant powers of attorney. The ADCR accepted the application on 26.10.2021, restoring the respondents' ownership. Appeals filed by the petitioners were later transferred to the Additional Commissioner (Rev.) Lahore, who set aside the ADCR's order and advised the respondents to approach civil courts. This decision was challenged through revision, which was accepted by the MBR on 29.01.2025.

18. The counsel refuted the petitioners' claim that the ADCR had no jurisdiction to review the mutations. It was submitted that the District Collector and subordinate officers are authorized under Section 163 of the Land Revenue Act to review and correct revenue entries. Support was drawn from PLJ 1992 Rev. 83.

19. Regarding jurisdiction, the counsel submitted that Section 53 of the Land Revenue Act is not attracted in this case because the power of attorney was void ab initio. Rather, under Section 172 of the Act, revenue authorities are competent to correct entries. Citing 2009 CLC 542 and 1983 CLC (Pesh.) 3156, it was argued that long-standing but fraudulent entries can be corrected without recourse to civil litigation when no complex question of fact exists.

20. It was argued that the certified copy of the civil court decree was never produced before the authorities until the review stage, and its late production carried no legal benefit. The learned counsel emphasized that a decree for specific performance must be executed through the executing court and a proper sale deed before it can affect the revenue record. Reliance was placed on PLD 2010 42 (Lahore). It was further argued that relevant government taxes and stamp duty must be paid before implementing any decree, and the applicable stamp rate is to be calculated as per the value at the time of registration, as held in 2016 SCMR 203.

21. The learned counsel contended that the mutation was not entered in the Roznamcha Waqiati, violating Section 42 of the West Pakistan Land Revenue Act. Additionally, the decree dated 27.07.1992 was allegedly implemented through mutation on 30.07.1996-well beyond the three-year limitation period. It was submitted that such delay rendered the decree unenforceable under Article 181 of the Limitation Act. Reliance was placed on 1996 SCMR 759, 2007 SCMR 929, PLD 1990 SC 778, 2013 SCMR 5, and 2007 SCMR 1929. It was further emphasized that failure to initiate execution within three years extinguishes enforceability. The counsel noted that no agreement to sell dated 15.01.1986 was ever produced to support the decree.

22. Regarding the Power of Attorney No. 4479, it was argued that it lacked specific details such as khasra, khata, or khewat numbers, and even the land quantum was unspecified. Citing PLJ 2021 Lahore (Note) 16, PLD 2013 SC 190, PLD 2005 SC 418, 2001 SCMR 1700, and PLD 1985 SC 341, it was contended that such an instrument lacked the authority to transfer land. Power of attorney must be construed strictly and cannot infer authority to gift or alienate property unless specifically provided.

23. It was further argued that the power of attorney was not even intended to authorize sale or gift of the disputed land. Reliance was placed on 2007 SCMR 1062 and PLD 2013 Lahore 95, which clarified that unauthorized acts under void powers of attorney confer no legal effect.

24. Further reference was made to Section 21 of the Registration Act, 1908, requiring proper description of property for registration. Judgments such as AIR 1928 Calcutta 385 were cited to assert that documents lacking property description are invalid, even if registered.

25. The learned counsel relied on 2004 YLR 288, 2001 SCMR 1700, and 2010 SCMR 1066 to reinforce that power of attorney must explicitly authorize any act of alienation and cannot be interpreted liberally. On fiduciary duties, it was submitted that attorneys cannot transfer property to themselves or their associates without the principal's explicit consent. In support, 2022 SCMR 1068 and 2016 SCMR 1781 were cited.

26. Regarding the gift mutations, the counsel submitted that such transfers via attorney are impermissible unless the donee is specifically nominated. Reliance was placed on 2021 SCMR 1298, 2016 SCMR 1781, PLD 2008 SC 389, and 2014 CLC 513, which established that attorneys cannot gift principal's property unless clearly authorized and the donee is identified.

27. On limitation, the counsel argued that the respondents resided in Lahore and became aware of the fraud only later. As fraud vitiates limitation, the application was timely upon discovery. Reliance was placed on 2002 SCMR 343, asserting that limitation runs from the date of knowledge. It was also submitted that the argument of time-barred application had no merit due to the fraudulent basis of the mutations.

28. Finally, the counsel argued that the revision petition had been rightly accepted through a speaking order, and that review under Section 8 of the Punjab Board of Revenue Act, 1957, has a limited scope. Since no jurisdictional or factual error exists in the impugned order dated 29.01.2025, the review petition is without merit and liable to be dismissed.

29. Record perused, and arguments have been heard.

30. After reviewing the record, it is evident that Mutation No. 586 dated 30-09-1999 was sanctioned on the basis of a civil court decree dated 27-07-1992. The record demonstrates that this decree remained unchallenged for more than a decade. Revenue officers, under the settled law, are duty bound to reflect such decrees into the revenue record and possess no jurisdiction to annul or question them. The jurisprudence laid down in PLD 2012 Lahore 160, 2008 SCMR 1658, and 2021 CLC 689 confirms this principle. The respondents' application, filed after more than 16 years, was clearly hit by limitation under the Punjab Land Revenue Act, 1967. Moreover, the application was filed against a deceased individual, and no valid proceedings can lie against a dead person. These jurisdictional and procedural flaws render the proceedings void ab initio. It is also noteworthy that the revenue forum lacks competence to adjudicate on allegations of fraud or title involving disputed facts, which require framing of issues and full trial-matters that fall exclusively within the domain of civil courts. The learned ACR had correctly appreciated these legal limitations in his order dated 29-07-2024. The learned Member (Judicial-VIII) did not appreciate these aspects and instead passed the impugned order dated 29-01-2025 without addressing the legal bar of limitation, absence of jurisdiction, and binding nature of the decree. The petitioners' certified copies were already on file, and the contrary observation in the impugned order is factually incorrect.

32. The central factual matrix reveals that the mutation entries challenged by the respondents-Mutations No. 586 dated 30.09.199 was sanctioned on the basis of a civil court decree dated 27-07-1992, which had attained finality and remained unchallenged for over three decades. In this context, the jurisprudential framework governing the implementation of civil court decrees through the revenue machinery becomes pivotal.

33. It is a trite principle of law, affirmed through an uninterrupted line of authority, that revenue officers are under a binding obligation to reflect civil court decrees in the revenue record and possess no jurisdiction to question, review, or override them. The mandate of Section 53 of the Punjab Land Revenue Act, 1967, coupled with authoritative guidance from the superior courts in PLD 2012 Lahore 160, 2008 SCMR 1658, and 2021 CLC 489, clearly establishes that the revenue hierarchy acts in execution of civil rights determined by the civil court and cannot function as a parallel appellate or supervisory body.

34. The legal question that arises is whether a revenue court can cancel a mutation lawfully entered in the revenue record on the basis of a decree of a civil court, and construe such mutation as a clerical or factual mistake on the pretext of alleged fraud. Had the mutation not been based on a decree, a different legal scenario might have emerged, even then, establishing fraud would remain a necessary legal threshold before any corrective action. It is legally untenable that a mutation rooted in a judicial decree has been labeled a mistake merely to circumvent the procedural rigour of approaching a civil court. Furthermore, the respondent's contention that a void decree is no decree and thus immune to limitation is contradicted by their own demand for execution of the same decree-thereby implicitly accepting its existence. This dichotomy exposes a clear logical inconsistency in the respondent's argumentation, which fails to withstand scrutiny under the established legal framework.

35. Further undermining the respondents' position is the procedural defect apparent at the outset. The application was filed purportedly on behalf of individuals who were admittedly deceased, rendering the proceedings a legal nullity from inception. This defect, coupled with the complete absence of recourse to a civil court to challenge the decree, strips the revenue forum of any jurisdiction. This conclusion finds reinforcement in 2021 SCMR 391, where it was categorically held that revenue courts exercise summary jurisdiction and lack competence to adjudicate questions of fraud, title, or complex civil rights arising out of civil litigation.

36. From an equitable standpoint, the conduct of the respondents also triggers the doetrines of acquiescence and estoppel. In 2002 SCMR 1330, 2020 YLR 666 and 2011 SCMR 222, the Hon'ble Supreme Court consistently held that parties who remain silent for prolonged periods and fail to challenge transactions in the proper forum, forfeit the right to belatedly question long-standing revenue entries-especially when those entries flow from judicial determinations.

37. Additional weight is lent to the petitioner's case by the validity of the decree and the transfer effceted through a registered General Power of Attorney. As held in PLD 1994 SC 336, 2004 SCMR 604 and PLD 2020 Lahore 478, such instruments can only be challenged before a civil court and not by way of administrative proceedings. The Additional Commissioner, in his reasoned order dated 29-07-2024, rightly appreciated the legal sanctity of the civil court decree, the bar of limitation, and the jurisdictional limitations inherent to the revenue hierarchy. That order merited deference and not reversal.

38. In contrast, due to non-presentation of complete certified copies of decrees of Civil Court as it was not traceable, the impugned order under review misapprehended both the factual substratum and the governing statutory scheme. It disregarded the binding principle that mutations based on judicial decrees cannot be reopened by revenue forums, overlooked the lapse of more than a decade, and ignored the jurisdictional mandate requiring civil court adjudication. These cumulative infirmities in law and fact leave no room for the impugned order to withstand judicial scrutiny and compel intervention in review.

39. After careful consideration, it is evident that the powers of attorney produced by the petitioners were valid, registered, and covered the land in village Saidpur. The mutation in question was sanctioned based on these documents, which were duly verified before the transaction. The learned Member (Judicial-VIII) erred in overlooking the documentary evidence and instead relied on a misapprehension of facts. The application of the respondents was not only delayed beyond the statutory limitation period but also involved disputed questions of title and allegations of fraud, which fall outside the jurisdiction of the revenue hierarchy. The superior courts have consistently held in PLD 1994 SC 336, 2004 SCMR

604. PLD 2020 Lahore 478 and 2014 CLC 1484 that such matters must be resolved by a civil court.

40. Furthermore, the principle of aequiescence and bar of limitation, as laid down in 2002 SCMR 1330, 2020 YLR 666 and 2011 SCMR 222, clearly apply. The respondents' silence for over a decade renders their belated challenge unsustainable. The learned ACR rightly considered all aspects and passed a well-reasoned order, while the order dated 26-10-2021 was both procedurally and substantively flawed.

41. The pivotal question requiring adjudication by this Court is whether a mutation duly sanctioned in the revenue record on the strength of a civil court decree can subsequently be annulled on the pretext of a clerical or factual mistake, premised upon allegations that the decree was non-existent, fraudulent, or otherwise void, or that the mutation was entered without execution of the decree, and that the power of attorney relied upon was legally insufficient to effectuate a transfer of title in favour of close relatives. The respondents, asserting the decree to be void ab initio, have taken the position that no recourse to a civil forum is required for redressal. In this backdrop, the core legal issue for determination is whether the revenue authorities, exercising summary jurisdiction, are vested with the competence to entertain and adjudicate such intricate and contentious claims-claims which inherently require the framing of issues, appreciation of documentary and oral evidence, and a full-fledged trial under the ordinary civil procedure. The revenue laws do not empower Revenue Courts to resolve such intricate and complex matters of civil litigation in a summary manner, which requires an exhaustive procedural framework to arrive at a final determination.

42. It is settled law that revenue authorities are creatures of statute and are confined strictly to the jurisdiction vested in them under the Punjab Land Revenue Act, 1967. They are not courts of plenary jurisdiction and cannot venture into questions that involve adjudication of civil rights, title, or allegations of fraud, which require framing of issues and recording of evidence. As held in PLD 2011 SC 512 and PLD 2010 SC 1, the moment a party alleges fraud or disputes title based on civil documents, the matter transcends the limited summary jurisdiction of the revenue forum. The appropriate remedy lies in a civil suit, where the parties can adduce evidence and obtain a binding declaration. Permitting revenue officers to cancel or mulify mutations rooted in registered documents and civil court decrees would not only amount to exceeding jurisdiction but would render such instruments legally uncertain, defeating the principles of finality and sanctity attached to judicial pronouncements and registered acts under the Registration Act, 1908. It is all the more ironic and legally untenable that the respondents, despite alleging fraud and having knowledge of the decree as per their own assertions, knowingly and deliberately avoided pursuing the appellate and remedial forums available under the civil law.

43. The scope of review under Section 8 of the Punjab Board of Revenue Act, 1957, is narrow and exceptional, requiring a demonstrable error apparent on the face of the record, or jurisdictional or legal misapprehension so fundamental as to vitiate the underlying order. The impugned order dated 29-01-2025, passed by the same Member (Judicial-VIII), departed from settled legal principles and disregarded material evidence that had formed the foundation of the earlier, well-reasoned order dated 29-07-2024. It proceeded on a misconstruction of both law and fact, failed to engage with the statutory limitations on revenue jurisdiction under the Punjab Land Revenue Act, 1967, and overlooked the evidentiary value of registered documents and civil decrees duly produced on record. This Court, therefore, is not reappreciating evidence, but correcting a manifest legal error that strikes at the very root of judicial consistency and jurisdictional propriety. The review is thus not only maintainable, but imperative to uphold the integrity of adjudication within the bounds of lawful authority it was compelled by the imperatives of justice, legality, and institutional discipline.

44. It is both ironic and perplexing that the respondents never availed themselves of the remedies available under the law by instituting any civil or criminal proceedings. No recourse was taken under the Code of Criminal Procedure, 1898, nor was any action initiated under the Pakistan Penal Code, 1860.

45. The learned counsel for the respondents has advanced weighty and well-reasoned arguments pertaining to the alleged commission of fraud, the mandatory requirement of a duly executed decree, the inapplicability of limitation in the peculiar circumstances of the case, and the validity, scope, and competence conferred by the General Power of Attorney. However, the pivotal issue remains whether a revenue court is legally vested with the jurisdiction to adjudicate upon such matters.

46. The respondents rely upon purposive meaning and interpretation rather than the literal interpretation of Sections 166 and 172(2)(vi) of the Punjab Land Revenue Act, 1967, Section 166 states: "Clerical or arithmetical mistakes in any decree or order made by any Revenue Officer, or errors therein from any accidental slip or omission may, at any time, be corrected by such officer." A literal interpretation confines this provision strictly to minor, non-substantive corrections arising from inadvertent slips or computational errors. Even under a purposive construction, the legislative intent behind this section is to maintain procedural accuracy-not to confer authority upon revenue officers to review or annul entries based on civil court decrees. Likewise, Section 172(2)(vi), which allows "the correction of any entry in a record-of-rights, periodical record or register of mutations," is designed for routine administrative corrections. Interpreted purposively, it does not empower revenue authorities to adjudicate complex disputes involving title, fraud, or the enforceability of decrees. Such matters lie exclusively within the jurisdiction of the civil courts.

47. Therefore, the District Collector is empowered to effect corrections in the revenue record only where the illegality or irregularity is manifest, apparent on the face of the record, and already established through a recognized legal or investigative process. Where the matter necessitates a detailed appraisal of evidence for the determination of such questions-particularly in matters involving allegations or commission of fraud, the validity or competence under a General Power of Attorney, the enforceability of a decree, the requirement of execution of a decree, or the applicability of limitation the jurisdiction of not only the District Collector, but all revenue courts stand ousted. In such circumstances, revenue courts lack the lawful competence to venture into adjudication of such complex and inherently civil disputes. Therefore, the respondent has no lawful grounds to seek relief from the revenue courts in a matter which squarely falls within the domain of civil adjudication.

48. In view of the foregoing, this petition is accepted. Consequently, the impugned order dated 29-01-2025, passed by the Member (Judicial-VIII), Board of Revenue, Punjab, is set aside. The order dated 29-07-2024, passed by the Additional Commissioner (Revenue), Lahore is upheld, and as a result, the earlier order dated 26-10-2021 passed by the Additional Deputy Commissioner (Revenue), Rahim Yar Khan, stands set aside. The respondents may seek appropriate relief before a Civil Court of competent jurisdiction, if so desired. File be consigned to record room after completion. MQ/14/Rev Petition allowed.