Chhattisgarh High Court Dismisses Second Appeal, Upholds Plaintiffs’ Title in Land Dispute

News Citation : 2026 LN (HC) 292 | 2026:CGHC:20123

April 30, 2026 : The Chhattisgarh High Court at Bilaspur has dismissed a second appeal filed by Kamla Bai, thereby affirming the findings of the First Appellate Court in a long-standing land dispute concerning property in village Chachedi, Marwahi tehsil.

The case arose from a civil suit filed by Sundi Bai and another, who sought declaration of title, recovery of possession, and cancellation of two sale deeds relating to agricultural land measuring 1.25 acres. The plaintiffs claimed that the land originally fell to their share through a partition order passed in 1979 and that their names were duly recorded in revenue records.

According to the plaintiffs, the dispute began when the father of some defendants allegedly got his name entered in the revenue records using fabricated documents. Although the plaintiffs initially succeeded in restoring their names through revenue proceedings, that order was later set aside in revision. Subsequently, the disputed land was sold to Kamla Bai in 2006, leading to further complications over ownership and possession.

The trial court had dismissed the plaintiffs’ suit, holding that they failed to conclusively establish title through reliable documentary evidence. It also found that the defendants were in possession based on a registered sale deed.

However, the First Appellate Court reversed this decision after re-evaluating the evidence. It held that the revenue records, including khasra and B-1 entries, consistently reflected the plaintiffs’ names following the partition proceedings. The appellate court also noted that the defendants failed to produce any valid document to substantiate their claim of ownership or lawful acquisition.

Challenging this reversal, the appellant argued before the High Court that the appellate court had wrongly interfered with well-reasoned findings of the trial court and had relied on presumptions rather than solid evidence.

Justice Bibhu Datta Guru, however, found no merit in these arguments. The court reiterated that the scope of interference in a second appeal under Section 100 of the Code of Civil Procedure is limited to substantial questions of law. It observed that the appellate court had properly appreciated the evidence on record and that its findings were neither perverse nor legally flawed.

The High Court emphasized that while revenue entries alone do not confer title, they remain relevant evidence when supported by other material. In this case, the consistent and unchallenged revenue records, along with supporting documents, were sufficient to uphold the plaintiffs’ claim.

Finding no substantial question of law, the court dismissed the appeal at the admission stage, effectively confirming the plaintiffs’ title over the disputed land.

Case Reference : SA No. 177 of 2020, Kamla Bai vs Sundi Bai and Others. Counsels: For the Appellant(s): Mr. Avinash Chand Sahu, Advocate (through VC), and Ms. Priya Sharma, Advocate; For Respondent No. 6: Mr. Jai Prakash Tiwari, Panel Lawyer.