The Supreme Court, in a judgment delivered on September 2, 2026, clarified that the provisions of the Limitation Act, 1963 cannot be invoked to extend or override the limitation period prescribed under the Karnataka Land Revenue Act, 1964 for exercising revisional powers. The observation was made by a bench comprising Justice Sanjay Kumar and Justice Sanjeev Sachdeva while hearing an appeal arising from a land dispute in Bengaluru.
The case centred on a notice issued in 2014 by the Joint Director/Registrar of Land Records under Section 56 of the Karnataka Land Revenue Act, 1964, proposing a fresh enquiry into land survey numbers in the Yediyur Lake area. The notice was based on a complaint alleging encroachment and was issued nearly four decades after the City Title Survey of 1974 had assigned CTS numbers to the land in question. The appellant, M.R.R. Setty (deceased), represented by his legal heirs, claimed ownership over 28 guntas of land in Bengaluru, purchased through eight sale deeds in 1929. Development permissions had been obtained from the BBMP, and an occupancy certificate was issued in 2006 for a residential apartment complex constructed on the land.
The appellant challenged the notice before the Karnataka High Court. A Single Judge quashed the notice, holding that the revisional power under Section 56(3) of the Act could not be exercised beyond the three-year limitation period from the date of the original order, in this case the 1974 survey. The Division Bench of the High Court, however, reversed this decision in January 2020, permitting the authorities to proceed with the fresh enquiry. A review petition filed by the appellant was dismissed in June 2023, after which he approached the Supreme Court. The appellant passed away in December 2024, and his legal representatives were brought on record.
Before the Supreme Court, the state government argued that the delay condonation provision of Section 5 of the Limitation Act, 1963 could apply mutatis mutandis to the revisional proceedings under the Karnataka Land Revenue Act. The Court rejected this contention, observing that the issue was not about filing an appeal under the Act but about the exercise of revisional powers by the authority under Section 56(1).
The bench noted that the proviso to Section 56(3) of the Karnataka Land Revenue Act, 1964 expressly limits the exercise of revisional power to three years from the date of the order, provided no appeal has been preferred against it. The Court emphasized that once the statute prescribes a clear and categorical limitation, the provisions of the Limitation Act, 1963 cannot be 'smuggled in' to negate or defeat that statutory embargo.
Justice Sanjay Kumar, authoring the judgment, stated that the Division Bench of the High Court had erred in reversing the Single Judge’s decision. The Court held that the invocation of revisional power by the Joint Director/Registrar of Land Records in 2014, more than three years after the 1974 survey order, had no foundation in the statute and was therefore vitiated at its inception.
The Court further observed that requiring the appellant or his successors-in-interest to participate in an enquiry based on a power exercised beyond the prescribed limitation could not be sustained. The Single Judge had been fully justified in interfering with the notice and allowing the writ petitions. The Division Bench’s contrary view was incorrect, and this error was compounded by the subsequent rejection of the review petition.
Accordingly, the Supreme Court allowed the appeal, quashing the notice issued under Section 56 of the Karnataka Land Revenue Act, 1964 insofar as it pertained to the land of the appellant. The judgment reaffirms that statutory limitation periods in special enactments like the Karnataka Land Revenue Act must be respected and cannot be displaced by general provisions of the Limitation Act, 1963 when the special law provides a complete and self-contained regime.