Mutation does not create any interest in property nor does it transfer any title. It is necessary for the payment of the property tax after the acquisition of the property through sale, gift, succession or inheritance. Mutation is simply the process of recording the name of the present owner of the property in the land records of the local revenue authorities for fiscal purposes after the change in ownership.
In Baleshwar Tewari/& Ors vs. Sheo Jatan & Ors on 20 March, 1997, SupremeCourt held that Entries in the revenue records is neither a proof of title upon the property nor can it be used as a camouflage to defeat the legal right, title or interest of a person, who is the owner of the property in question. Revenue entries neither can confer a title nor can it extinguish the right of title of the owner of the property.
In Smt. Sawarni vs. Smt. Inder Kaur and Others on 23 August, 1996, Supreme Court of India held that Mutation of the property in the revenue record also does not create or extinguish title nor has any presumptive value on title. It only enables the person in whose favor mutation is ordered to pay land revenue in question.
Thus, the correct proof of ownership is a registered sale deed, gift deed or will in favor of the person. Revenue entries or revenue receipts have nothing to do with the ownership and they cannot be treated as conclusive evidence of the ownership of the property.
Mutation entries are relevant only so far as they indicate the nature and contents of records of revenue authorities made at the time of mutation but they do not prove relationship between the persons mutated and the persons in whose place he is so mutated.