Law: Constitution of Pakistan, 1973

Section: 199

Law: Punjab Land Revenue Act, 1967

Section: 166, 172(2)(vi), 42, 44, 52, 53

Law: Specific Relief Act, 1877

Section: 42

Summary The Supreme Court dismissed the petition and held that century-old, unimplemented mutations cannot be enforced through summary revenue proceedings under Section 166 of the Punjab Land Revenue Act, especially where serious factual controversies and third-party rights are involved. Such matters require adjudication by a civil court through a declaratory suit, not by revenue authorities or in constitutional jurisdiction. The Court further held that laches, acquiescence, and delay (over 100 years) bar relief, and writ jurisdiction under Article 199 cannot be invoked for resolving disputed questions of title. Tag Line "Old and disputed mutations cannot be revived through revenue proceedings; title disputes belong to civil courts, not writ jurisdiction." ORDER; Syed Hasan Azhar Rizvi, J.- The petitioners have filed the present petition under Article 175F(1)(c) (though inadvertently mentioned as 185(3)) of the Constitution of the Islamic Republic of Pakistan, 1973 (‘the Constitution'), to impugn the legality of the judgment dated 06.10.2025 passed by the Lahore High Court, Lahore (‘the High Court'), whereby a writ petition filed by the petitioners under Article 199 of the Constitution, challenging the order of the Member (Judicial), Board of Revenue (‘M.B.R.'), Punjab was dismissed. By the said order, the M.B.R., while accepting the revision petition filed by respondents Nos. 4 and 5 (hereinafter referred to as ‘the private respondents'), set aside the order passed by the Additional Commissioner and restored the order of the Additional Deputy Commissioner (Revenue), whereby the application filed by the present petitioners for implementation of mutations in favour of their predecessors-in-interest was dismissed. At the outset, and before addressing the substantive legal issues, it is necessary to recapitulate the essential facts that constitute the backdrop of the present petition. Per record, it is the stance of the petitioners that their predecessor-in-interest, as well as that of the proforma respondents Nos. 7 to 14, namely Bakhtan, Ahmad Khan, and Siddique Khan, were owners of the disputed land on the basis…