Supreme Court of India (Division Bench (DB)- Two Judge)

Appeal (Civil), 2749 of 2015, Judgment Date: Mar 10, 2015


                                                                  REPORTABLE

                        IN THE SUPREME COURT OF INDIA
                        CIVIL APPELLATE JURISDICTION

                       CIVIL APPEAL NO.  2749  OF 2015
                  (Arising out of SLP (Civil) No.3172/2014)


THE REVENUE DIVISIONAL OFFICER                            ... Appellants
FORT, KOCHI & ORS.

                                   Versus

JALAJA DILEEP & ANR.                                   ...  Respondents

                                    WITH

                       CIVIL APPEAL NO. 2750   OF 2015
                   (Arising out of SLP (C) No. 16851/2014)
                       CIVIL APPEAL NO. 2751  OF 2015
                   (Arising out of SLP(C) No. 26518/2014)
                       CIVIL APPEAL NO. 2752  OF 2015
                   (Arising out of SLP (C) No. 27218/2014)
                       CIVIL APPEAL NO. 2753   OF 2015
                   (Arising out of SLP (C) No. 32231/2014)
                                     AND
                       CIVIL APPEAL NO. 2754  OF 2015
                   (Arising out of SLP (C) No. 1135/2015)


                               J U D G M E N T

R. BANUMATHI, J.

Delay condoned in SLP (C) No.32231 of 2014 and  leave  granted  in  all  the
special leave petitions.
2.           This  bunch  of  appeals   raises   question   of   substantial
importance, whether the order of conversion of land passed by the  Tahsildar
under Kerala Land Tax Act would  circumvent  the  provisions  of  beneficial
legislations such as Kerala Conservation of Paddy and Wetland Act, 2008  and
the Kerala Land Utilization Order, 1967?
3.          These appeals arise out of the order  passed  by  the   Division
Bench of the Kerala High  Court,  which  upheld  the  order  passed  by  the
learned Single Judge and thereby directing the Tahsildar to effect a  change
in the Basic Tax Register (BTR) and correct the nature of land from  'Nilam'
(Wetland) to 'Purayidam' (Dry  land).    For  convenience,  facts  in  civil
appeal arising out  of  Special  Leave  Petition  (C)  No.3172  of  2014  is
referred to and taken as the lead case.
4.          Briefly stated facts of the case are as under:- Respondent  No.1
herein is the joint owner of  the  land  comprised  in  Survey  No.330/2  of
Ernakulam Village in Ernakulam District to an extent of  12.286  cents.  The
respondents approached the Agricultural Officer who gave  a  certificate  on
10.2.2012, to the effect that  the  land  in  question  was  recorded  as  a
converted land in the Paddy Wetland  in  the  survey  records  in  Ernakulam
Village and additionally, a possession certificate was also  issued  by  the
Village Officer on 15.2.2012, wherein it  was  reported  that  the  land  in
question is actually a dry land.  When the heirs of  the  respondents  tried
to sell the land, the purchasers of the land insisted for production  of  an
order showing nature of land as a dry land, as  a  condition  precedent  for
registering sale deed, but the revenue authorities refused  to  correct  the
same.
5.          The respondent No.1 filed a  Writ  Petition  No.11784  of  2012,
before the High Court seeking a writ  of  mandamus  to  the  authorities  to
effect necessary corrections in  the  Basic  Tax  Register  and  change  the
nature of lands from 'wetland'  to 'dry  land'.    Respondent  No.1  averred
that the disputed property is  a  dry  land,  but  wrongly  described  as  a
wetland (Nilam) in their sale deed and  that  it  was  never  used  for  any
agricultural purposes.  The Single Judge of the High Court vide Order  dated
13.7.2012, allowed the writ petition directing  that  the  property  of  the
respondent No.1 will have to be classified  as  'reclaimed  purayidam'  (dry
land) in the Basic Tax Register (for  short  'BTR')  and  further  issued  a
direction to the Tahsildar and the Village  Officer  to  effect  appropriate
correction as per the terms of  the  direction.   Aggrieved  by  the  Order,
State preferred W.A. No.412 of 2013, wherein the Division Bench of the  High
Court vide impugned judgment dated 2.1.2014, upheld the order of the  Single
Judge and dismissed the appeal.  Aggrieved, the State of  Kerala  has  filed
this appeal by way of special leave assailing the impugned judgment.
6.           Learned  senior  counsel  for  the  appellants  contended  that
without making an application for conversion of nature of  land  before  any
statutory authority, writ proceedings were initiated by respondent No.1  and
the impugned order would circumvent the provisions  of  Kerala  Conservation
of Paddy and Wetland Act, 2008 and the Kerala Land Utilization Order,  1967.
  It was submitted that 'Nilam' (wetland) in due course had been changed  or
transformed into reclaimed 'purayidam'  dry  land  or  any  other  state  of
condition and the change so effected or made by itself will  not  amount  to
'a mistake' as referred to in Section 18 of Kerala  Land  Tax  Act  and  the
Tahsildar has absolutely no competence to decide upon  the  reclassification
application in respect of the correction of BTR and the  impugned  order  is
liable to be set aside as they are in contravention  of  provisions  of  KLU
Order, 1967 and Kerala Conservation of Paddy and Wetland Act, 2008.
7.          Per contra,  learned  counsel  for  respondents  contended  that
since District Collector declined to make necessary changes in the  BTR,  in
exercise of power under Article  226  of  the  Constitution,  Tahsildar  was
rightly directed to make necessary changes  in  the  BTR  and  the  impugned
order does not contravene the provisions of the Acts.
8.          We  have  considered  the  rival  contentions  and  perused  the
impugned order and materials on record.  Before going  into  the  merits  of
the contentions and the impugned order,  it is imperative to  refer  to  the
scheme of the relevant Acts.
9.          Scheme and Object of Land Utilization Order,  1967:  The  Kerala
Land Utilization  Order,  1967  ('KLUO'  for  brevity)  was  issued  by  the
Government of Kerala under the Essential Commodities Act 1955 (10  of  1955)
at a time when India was facing food grain deficit and there were also  some
restrictions on inter-State movement of food grain.  The object of KLUO is:-
 (a) to bring occupied waste or  arable  lands  likely  to  be  left  fallow
during a cultivation season under  cultivation  with  paddy  or  other  food
crops;  (b) to prevent the conversion  of  any  land  cultivated  with  food
crops for other purpose, except with the written permission of the  District
Collector or the Revenue Divisional Officers in case the powers of  District
Collectors have been delegated to them.
10.         Clause 3 of the Order provides that  the  State  Government  may
direct, every holder of land shall grow over such portion of his  land  food
crops such as  paddy,  fish,  sugarcane,  vegetables,  tapioca,  yarn,  tea,
coffee, cardamom, pepper, ground-nut cocoa and banana  in  addition  to  any
crop he may have grown over such land.  Clauses 4 to 7  postulate  the  role
of Collector in implementing the object of the Act and the sanctions he  can
impose in case of non-compliance by holder of land. Clause 6  of  the  order
provides that land cultivated with any food crop for a continuous period  of
three years shall not be converted or utilized for cultivation of any  other
food crop or for any other purpose except with  the  written  permission  of
the Collector.  Clause 7 of the Order empowers the Collector  to  call  upon
any person who contravenes the provisions of  KLUO  to  cultivate  the  land
with such food crops and within such period  as  may  be  specified  in  the
notice.  If the notice is not complied with within the time  specified,  the
Collector may,  by order direct and arrange for the sale by public  auction.
  Thus,  the  KLUO  vests  District  Collectors  with  powers   to   enforce
cultivation of food crops.
11.         Further vide Notification No. G.O. (Rt.) No.  157/2002/AD  dated
5.2.2002, Government of Kerala,  Agriculture  (NCA)  Department  has  issued
instructions to follow the modalities for implementation of the  KLU  Order,
wherein conversion for construction of houses for individuals are  permitted
and it reads as under:
The direction issued to District Collectors vide  reference  read  as  first
paper (Government letter No. 47165/NCA-3/97/AD  dated  17.12.1997)  will  be
withdrawn.   This  would  mean  that  applications  for  conversion  can  be
considered  and  disposed  off  by  Revenue   Divisional   Officers/District
Collectors in accordance with the provisions of the KLU  Order  and  related
standing instructions.  The Land Revenue Commissioner will hear appeals  and
the Government (in the  Agriculture  Department)  will  exercise  revisional
powers as provided for in the KLU Orders.
District Collectors will ensure the conversions, which are likely to  render
irrigation investments infructuous, are not to be allowed.  Similarly  large
scale conversion for Commercial purpose should be discouraged.
In all cases, where conversion  is  allowed,  Collectors/Revenue  Divisional
Officers must ensure that drainage for neighbouring or nearby plots  is  not
blocked or rendered impossible.
Conversion of land for  construction  of  houses  for  individuals,  upto  5
cents, should generally be  allowed.   However,  large-scale  conversion  of
land by artificial partitioning into  small  plots  of  less  than  5  cents
should be detected and disallowed.
The revenue machinery at the taluka and village-level  should  be  activated
to ensure that in future,   conversions  or  attempted  conversions  without
sanction are promptly detected and proceeded  against.   Conversions  should
not presented as a 'fait accompli' which have to be inevitably regularized.
Government   will   examine   the   suggestions   of    Collectors/Principal
Agricultural Officers for changes  to  the  KLU  Order  to  make  the  penal
provisions more effective and also for levying as on conversion.

12.         Scheme and Object of the Kerala Conservation of Paddy  Land  and
Wetland  Act,  2008  (for  short   'Wetland   Act'):-   Indiscriminate   and
uncontrolled reclamation and massive conversion of paddy  land  and  wetland
that were taking place in the  State  led  to  the  passing  of  the  Kerala
Conservation of Paddy and Wetland Act, 2008 with  an  aim  to  conserve  the
paddy land and  wetland  and  to  restrict  the  conversion  or  reclamation
thereof, in order to promote  growth  in  the  agricultural  sector  and  to
sustain the ecological system in the State of Kerala.
13.         Section 2 (xii) of the Act of 2008 defines "paddy land"  as  all
types of land situated in the State where paddy is cultivated at least  once
in a year or suitable for paddy,   cultivation  but  uncultivated  and  left
fallow,  and  includes  its  allied  constructions  like  bunds,    drainage
channels,  ponds and canals.  Further,  as  evident  from  the  objects  and
scheme of the Act, whether a land in question would come  under  paddy  land
defined in Conservation of Paddy Land  and  Wetland  Act,  2008,  is  to  be
determined on the basis of facts as they exist on  ground  and  not  on  the
basis of description in the revenue records or in the deeds.  Section  3  is
the pivotal provision of the Act which prohibits conversion  or  reclamation
of  paddy  land.   As  per  Section  3,   that  on  and  from  the  date  of
commencement of this Act, the owner, occupier or the person  in  custody  of
any paddy land shall not  undertake  any  activity  for  the  conversion  or
reclamation of such paddy land except in accordance with the  provisions  of
this Act.  Section 13 read with Section 3 provides that  District  Collector
is empowered to order re-conversion of  the  land  only  if  reclamation  or
conversion was made after the commencement of the provisions of the Act.
14.         To ensure the  proper  implementation  of  objectives,  the  Act
envisages the constitution of Committees  at  three  different  levels  i.e.
Local Level Monitoring Committee (S.5),  State  Level  Committee  (S.8)  and
District Level Authorized Committee (S.9).  Besides  it,  Wetland  Act  also
provides for the reporting officers under  Section  7  who  are  Agriculture
Officers  vested  with  responsibility  to  report  the  Revenue  Divisional
Officer as well  as  to  Committees,  regarding  any  act  in  violation  of
provisions of the Act.
15.         The Act provides for a local-level monitoring committee in  each
panchayat or municipality for monitoring  the  implementation  of  the  Act.
The powers of the Committee are conferred under sub-section (3)  of  Section
5.  Sub-section (ii) of Section 5(3),  vests the power  to  Local  Committee
to inspect the paddy land situated within the jurisdiction of the  Committee
to monitor whether the provisions of the Act are  being  complied  with  and
the same has  to  be  reported  to  the  Revenue  Divisional  Officer.   The
Committee can examine complaints from the public about attempts  to  violate
the provisions of the Act and intervene to  prevent  violation.  Under  sub-
section 4(iv) of Section 5, the Committee has got the  function  to  collect
the details of the paddy  land  within  the  area  of  jurisdiction  of  the
Committee,  reclaimed in contravention of the provision of any law  for  the
time being in force, before the date of commencement of the Act and to  give
the report to the Revenue Divisional Officer.
16.         The Local Level Monitoring Committee is empowered  to  recommend
to the State-Level Committee or the District-Level Authorized Committee,  as
the case may be, the reclamation of paddy land for  public  purpose  or  for
construction of residential buildings for the owner of the land, subject  to
conditions fixing the extent of the land to  be  so  utilized.   The  State-
Level Committee has to scrutinize each application recommended by the local-
level committee for filling up or  reclamation  of  paddy  land  for  public
purpose. It should examine in detail if alternative  land  is  available  in
the area for the purpose and the ecological  changes  that  may  occur  from
reclamation.
17.         "Paddy land" and "Wetlands" are defined under Sections  2  (xii)
and 2 (xviii) of the Act respectively. As per Section  5(4),  the  Committee
shall interalia prepare a Data Bank with details of  cultivable  paddy  land
within the jurisdiction of the Committee.   If the land  is not included  in
the Data Bank  or Draft Data Bank prepared under the Kerala  Cultivation  of
Paddy Land and Wetland Act  2008  and  if  it  is  not  a  "Paddy  Land"  or
"Wetland" as defined  under Act 28 of 2008,  at the time of commencement  of
the Act 12 of 2008 and the classification of land is  noted  as  "Nilam"  in
the revenue records, the provision of Kerala  Land  Utilization  Order  1967
will be applicable to such land and the Collector as defined in clause  2(a)
of KLU Order 1967 has the power to grant permission to utilize the land  for
other purposes.  As stated in clause 2 (a) of KLU  Order,  Collectors  shall
examine such request for residential purpose, on merits on a  case  to  case
basis.   However,  with a view to prevent indiscriminate  filling  of  Paddy
Lands  in  the  State,  the  Government  have   also    prescribed   certain
restrictions in the Notification dated 5.2.2002  noted  (supra),   in  which
District Collectors  have  been  directed  interalia   to  ensure  that  the
conversions which are likely to render  irrigation  investments  infructuous
and large scale conversion for commercial purpose are not allowed.
18.         If a property is included in the Data Bank  or  the  Draft  Data
Bank prepared under the Wet Land Act 2008 as a  "Paddy  Land"  or  "Wetland"
and the classification of land is noted  as "Nilam" in revenue records,  the
provisions of the Act 28/2008 would apply.  As  noticed  earlier,  there  is
ample provision within the Act  to  grant  permission   for  such  land  for
residential purpose or public  purpose  as  defined  in  the  Act.   And  as
elaborated earlier, if the property is not included  in  the  Data  Bank  as
"Paddy Land" or "Wetland"  as  defined  under  Act  28/2008,   it  is  still
governed by the provisions of KLU Order 1967.  Thus,  State  of  Kerala  has
two statutes -KLU Order 1967  and  Kerala  Cultivation  of  Paddy  Land  and
Wetland Act  2008  each  dealing  with  delineated  areas  with  respect  to
preservation, management and process  of  reclamation  of  agricultural  and
paddy land for any other legitimate use.
19.         Kerala Land Tax Act 1961 is an Act to provide for levy of  basic
tax of land in the State of  Kerala.   High  Court  directed  correction  of
Basic Tax Register (BTR) under Section 18 of Kerala Land Tax  Act  to  order
change of nature of land.  The  change  of  nature  of  the  land  with  the
passage of time cannot be regarded as a conversion which  can  be  rectified
under Section 18 of the  KLT  Act.  Section  18  of  KLT  Act  provides  for
rectification of mistakes. Section 18 reads as follows:-
"18.   Rectification of mistakes.-At any time within four   years  from  the
date of any order passed by it the prescribed authority   or  the  appellate
authority or the revisional authority  may, on its own motion, rectify   any
mistake apparent from the record and shall, within a  like  period,  rectify
any such  mistake  which  has  not  been   brought  to  the  notice  of  the
prescribed  authority  or  the  appellate  authority   or   the   revisional
authority, as the case may be, by a land-holder or other  person  liable  to
pay tax:
      Provided that no such  rectification  shall  be  made  which  has  the
effect of enhancing the tax payable unless  the  landholder  and  any  other
person liable to pay tax have been given a reasonable opportunity  of  being
heard in the matter."

20.         By the perusal of the above provision, it is  evident  that  the
rectification of mistake narrated in Section  18  relates  to  the  apparent
mistake on the face of the record in relation to any  order  passed  by  the
prescribed authority,   appellate  authority  or  the  revisional  authority
under the Act. Therefore, the  rectification  of  mistake  can  only  be  in
respect  of  proceedings  or  orders  passed  by  the  original   authority,
appellate authority or the revisional authority.
21.         Statutory enquiry to ascertain whether  the  land  is  a  "Paddy
Land" or "Wetland" and conversion of the land  for  residential  purpose  or
for any public purpose is governed by KLU Order or the Kerala  Wetland  Act,
2008 for conversion of the land from "Nilam" (Wetland) to  'Purayidam'  (Dry
Land).   The concerned authorities constituted under  KLU  Order  or  Kerala
Wetland Act 2008 are the competent authority.   Nature of  the  land  cannot
be changed or converted by directing  changes  in  the  Basic  Tax  Register
which is maintained only for the purpose of   land  tax.  The  rectification
envisaged by Section 18 of Kerala Land Tax Act can only  be  in  respect  of
arithmetical or clerical error, that too in the  order  of  determining  the
tax due.  Section 18 cannot be made use or the same cannot  be  taken  as  a
means to effect conversion  of  the  nature  of  the  land  bye-passing  the
competent authority and the procedure stipulated under the KLU  Order,  1967
and the Kerala Wetland Act, 2008 and the impugned  judgment  is   liable  to
be set aside.
22.         For the foregoing reasons, the impugned judgment passed  by  the
High Court in Writ Appeal  No.412/2013  is  set  aside  and  the  appeal  is
allowed. Accordingly impugned judgments in connected matters  are  also  set
aside and the appeals are allowed.
23.         The respondents in all the appeals are directed to approach  the
competent authorities constituted under KLU Order  1967/Kerala  Conservation
of Paddy Land and Wetland Act 2008 as the case may be for conversion of  the
land. When the respondents approach the  concerned  authorities  constituted
under the above statutes,  the  concerned  authorities  shall  consider  the
application of the respondents in accordance with  the  relevant  provisions
of the statutes and also the  notification  G.O.(Rt.)  No.157/2002/AD  dated
5.2.2002 already extracted above in para  11  and  in  accordance  with  law
keeping in view the factual position that may be brought to  the  notice  of
the authorities alongwith material to  substantiate  their  claim.   In  the
facts and circumstances of the case, we make no order as to costs.

                                           ...............................J.

                                                           (V. GOPALA GOWDA)


                                            ..............................J.

                                                        (R. BANUMATHI)

New Delhi;
March 10, 2015

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