- 1 - HC-KAR NC: 2025:KHC:44566 WP No. 26469 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 5TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV WRIT PETITION NO. 26469 OF 2025 (KLR-RES) BETWEEN: 1. SRI MUNIRAJU M S/O LATE MUNISWAMAPPA AGED ABOUT 56 YEARS RESIDING AT MUGALURU VILLAGE SARJAPURA HOBLLI, ANEKAL TALUK BENGALURU - 562 125 … PETITIONER (BY SRI. SURYA S., ADVOCATE FOR SRI SIJI MALAYIL., ADVOCATE) AND: 1. THE STATE OF KARNATAKA REPRESENTED BY PRINCIPAL SECRETARY REVENUE DEPARTMENT VIDHANA SOUDHA BANGALORE - 560 001 2. THE SPECIAL TAHSILDAR ANEKAL TALUK BANGALORE - 562 106 3. THE ASSISTANT COMMISSIONER BANGALORE SOUTH SUB DIVISION Digitally signed by VIDYA G R Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:44566 WP No. 26469 of 2025 KANDAYA BHAVAN, BANGALORE - 560 009 … RESPONDENTS (BY SMT. NAVYA SHEKHAR, AGA) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT IN THE NATURE OF MANDAMUS, DIRECTING THE RESPONDENTS TO CONSIDER AND ACT UPON THE REPRESENTATION DATED 03-03-2025 SUBMITTED BY THE PETITIONER (ANNEXED AS ANNEXURE-K), AND TO FORTHWITH IMPLEMENT THE INTERIM ORDER OF INJUNCTION PASSED BY THE HON'BLE SENIOR CIVIL JUDGE AND JMFC, ANEKAL, IN O.S. NO. 1076/2014 VIDE ANNEXURE-F BY INCORPORATING THE SAME IN THE OTHER RIGHTS COLUMN OF THE RELEVANT REVENUE RECORDS DATED 06.01.2021 AND ETC. THIS PETITION COMING ON FOR PRELIMINARY HEARING THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV ORAL ORDER Petitioner has filed the present petition seeking for issuance of writ in the nature of mandamus to direct the respondents to consider and act upon the representation dated 03.03.2025. 2. In terms of the representation at Annexure-K, the petitioner submits that he is the owner to an extent of 5 acres 8 guntas in Sy. No. 127/1 of Mugaluru Village, - 3 - HC-KAR NC: 2025:KHC:44566 WP No. 26469 of 2025 Sarjapura Hobli, Anekal Taluk, Bangalore Urban District. It is stated that there were certain civil disputes between the petitioner and other persons in O.S.No. 1076/2014. It is further submitted that the pendency of proceedings in O.S.No. 1076/2014 was requested to be entered in the revenue records in light of the defendants in the said suit making efforts, to alienate the property and create third party rights. Petitioner however submits that in O.S.No. 1076/2014, the Court had allowed I.A.No.8 filed under Order 39 Rules 1 and 2 read with Section 151 of CPC and the defendants in the said suit are restrained from alienating or from encumbering the suit schedule property. 3. Reliance is placed on the order passed in W.P.No. 1168/2025 to contend that the Co-ordinate Bench had considered the aspect of entry of judicial proceedings in revenue records and held that even if the Revenue Authorities or State are not parties to the said proceedings, there is an obligation to make entry of the proceedings of the Court in RTC. - 4 - HC-KAR NC: 2025:KHC:44566 WP No. 26469 of 2025 4. The observations of the Court in Para Nos. 5 to 7 are as follows: "4. The principles governing the grant of injunctions, particularly in cases of "not to alienate" orders, are well-settled in law. The purpose of such an injunction is to prevent the creation of third-party interests and to ensure that the rights of the parties to the suit are preserved pending adjudication. An injunction restraining alienation serves to maintain the status quo, preventing unscrupulous parties from frustrating the decree that may ultimately be passed in the suit. The civil courts, while exercising their jurisdiction under Order 39 Rules 1 and 2 of the CPC, grant such reliefs to prevent irreparable injury, multiplicity of proceedings, and the possibility of third parties getting entangled in prolonged litigation due to unlawful alienation. It is, therefore, imperative that revenue authorities acknowledge and implement such orders to uphold the rule of law. 5. Revenue officials declining to give effect to injunction orders on the premise that they are not parties to the suit defies logic and the fundamental principles of judicial process. In - 5 - HC-KAR NC: 2025:KHC:44566 WP No. 26469 of 2025 adversarial litigation, a competent civil court exercises its discretion and grants injunctions to protect rights and prevent illegal transactions. The duty of revenue authorities is to ensure compliance with such judicial directions, not to insist upon being arrayed as parties to the suit to fulfill their statutory obligations. Revenue records, including the Record of Rights, serve as critical documents reflecting existing legal rights, and the refusal to incorporate injunction orders merely because revenue officials were not party to the proceedings is an abdication of duty. Such reasoning not only undermines the authority of the civil courts but also paves the way for fraudulent transactions and multiplicity of litigations, which the injunction orders seek to prevent. Hence, the argument that revenue authorities must be made parties to a suit before they can act upon an injunction order is wholly untenable and contrary to established legal principles. 6. The impugned endorsement by the Tahsildar is based on a circular that has already been judicially scrutinized. A Co-ordinate Bench of this Court, in the unreported judgment of Manjunath v. State of Karnataka & Others, decided on 21.12.2020, explicitly held that an interim - 6 - HC-KAR NC: 2025:KHC:44566 WP No. 26469 of 2025 injunction granted by a civil court falls within the purview of Section 127(1)(b) of the Karnataka Land Revenue Act. Consequently, revenue authorities are legally bound to reflect the injunction orders in the "other rights" column of the revenue records. The reasoning adopted by the Co-ordinate Bench lays emphasis the necessity on implementing court orders to prevent fraudulent transactions and further litigation. 7. In light of the principles governing injunctions and the authoritative pronouncement of this Court in Manjunath v. State of Karnataka, it is evident that the impugned endorsement is unsustainable. Revenue authorities, as custodians of land records, are duty bound to comply with orders of the civil court and ensure that rights declared by judicial forums are given full effect. Failure to do so would not only amount to willful disobedience of court orders but would also encourage illegal transactions in derogation of the rights of the litigating parties." 5. Taking note of the above observations, it is clear that in terms of the order of the Co-ordinate Bench, there is an obligation by the revenue authorities to reflect - 7 - HC-KAR NC: 2025:KHC:44566 WP No. 26469 of 2025 injunction order in “other rights” column of revenue records. In light of the same, respondent No.2 is directed to consider the representation of the petitioner at Annexure-K and take steps to make entries of orders of the Civil Court in “other rights” column of the revenue records, within a period of two weeks from the date of receipt of certified copy of this order. 6. It is noticed that several petitions are being filed by similarly placed parties placing reliance on the order passed in W.P.No. 1168/2025. In light of the settled position of law and noticing that the observations made by the Court in W.P.No. 1168/2025 regarding making entries of orders of Civil Court in “other rights” column of revenue records, having attained finality, it would be inequitable to drive similarly placed persons to come before the Court to seek for identical reliefs when position of law is settled and binding on the revenue authorities. - 8 - HC-KAR NC: 2025:KHC:44566 WP No. 26469 of 2025 7. Accordingly, copy of the order to be marked to the Revenue Secretary, Government of Karnataka to take note of the order passed in W.P.No. 1168/2025 and consider passing of a circular to such effect obviating the necessity of similarly placed parties from approaching the Court where request is only for making entry of pending civil proceedings in the revenue records. 8. With the above observations and directions, the writ petition is disposed of. Sd/- (S SUNIL DUTT YADAV) JUDGE VP