5_IMP_Adverse Possession Case Study

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CASE STUDY 1: Permissive Possession Turning Hostile?

Facts

A allows B to cultivate land without rent due to family relations.
B remains in possession for 25 years.
Revenue record continues in A’s name.
B later claims ownership by adverse possession.

Issue

Whether permissive possession can mature into adverse possession?

Held

❌ No

Law Applied

Permissive possession never becomes adverse unless there is clear hostile repudiation.

Case Law

📌 Thakur Kishan Singh v. Arvind Kumar
(1994) 6 SCC 591

“Possession initially permissive cannot become adverse unless the possessor openly asserts hostile title.”

Result

A succeeds.

🧪 CASE STUDY 2: Long Possession Without Hostility

Facts

B occupies government land openly for 30 years.
No document of ownership.
No objection raised by authorities.
B claims adverse possession.

Issue

Whether long, uninterrupted possession is sufficient?

Held

❌ No

Law Applied

Long possession alone does not satisfy adverse possession.

Case Law

📌 Karnataka Board of Wakf v. Govt. of India
(2004) 10 SCC 779

“Possession must be hostile, open, and to the knowledge of the true owner.”

Result

Claim rejected.

🧪 CASE STUDY 3: Tenant Claiming Adverse Possession

Facts

B enters land as tenant under A.
After expiry of tenancy, B continues possession for 15 years.
B claims adverse possession.

Issue

Whether tenant can claim adverse possession against landlord?

Held

❌ No, unless tenancy is repudiated.

Case Law

📌 Mohan Lal v. Mirza Abdul Gaffar
(1996) 1 SCC 639

“Tenant must first surrender possession or clearly deny landlord’s title.”

Result

Landlord succeeds.

🧪 CASE STUDY 4: Mutation Entry vs Title

Facts

B’s name is mutated in revenue records.
A remains silent for 12 years.
B claims ownership by adverse possession.

Issue

Whether mutation proves adverse possession?

Held

❌ No

Case Law

📌 Balwant Singh v. Daulat Singh
(1997) 7 SCC 137

“Mutation entries do not confer title nor prove adverse possession.”

Result

True owner protected.

🧪 CASE STUDY 5: Co-owner Claiming Adverse Possession

Facts

A and B are co-owners.
B alone remains in possession for 40 years.
B claims adverse possession against A.

Issue

Can one co-owner claim adverse possession?

Held

❌ Only if ouster is proved

Case Law

📌 P. Lakshmi Reddy v. L. Lakshmi Reddy
AIR 1957 SC 314

“Mere exclusive possession by one co-owner does not amount to ouster.”

Result

Claim fails.

📌 MASTER RULE (EXAM GOLDEN LINE)

“Adverse possession must be hostile, open, continuous, and to the knowledge of the true owner. Mere long possession, permissive occupation, or silence of the owner is insufficient.”

🏆 JUDICIARY EXAM HOTLIST (Repeat Topics)

✔️ Permissive possession
✔️ Tenant vs landlord
✔️ Co-owner ouster
✔️ Government land
✔️ Mutation entries

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