The Supreme Court advocates modern, conclusive digital land titling with technology like blockchain, reforms outdated laws, and promotes uniform, transparent land records to reduce disputes and enhance property ownership security.

Why in the News?

Recently, Supreme Court in Samiullah v. State of Biharcase has called for a fundamental reform in country's land registration and titling system.

K Gopi v Sub Registrar Case (2025)

Supreme Court held that Registration Act,1908 does not empower sub-registrars to check title or ownership and that their role is merely ministerial, with their only mandate being to verify that the paperwork is in order and the parties have signed it voluntarily.

The Supreme Court of India struck down Bihar's rule making mutation proof mandatory for property registration, reaffirming that registration records transactions, not ownership.
- It reiterated that document registration under the Registration Act, 1908, only records a transaction, while mutation (updating revenue records) is a separate process that doesn't confer title.
The Court criticized the "bureaucratic loop" created by outdated land records in India and suggesting a national push for modern, digital, conclusive titling to establish clear ownership.

Land Registration System in India

Land is a "State subject" and registration of deeds is a concurrent list subject under the Schedule VII of the Constitution.

Issues with the existing Land Registration System in India

Outdated legal framework: India's property transaction system continues to operate under colonial framework governed by century-old statutes i.e. Transfer of Property Act, 1882, Indian Stamp Act, 1899, and Registration Act, 1908.
No Conclusive Title: Registration of sale deed under Registration Act does not guarantee ownership instead it only serves as a public record of transaction having presumptive evidentiary value and not conclusive proof of title.
Litigation burden: Fake and fraudulent property documents, land encroachments, verification delays, system of presumptive title through registration, and fragmented state-level procedures leads to 66 percent of all civil litigation.
Administrative problems: Physical presence of buyer, seller, and two witnesses for verification, authentication and recording at sub-registrar offices makes land registration cumbersome and time-consuming.
- Moreover, since land is a state subject, procedures differ across States, resulting in fragmentation and lack of uniformity.
Incomplete Digitisation: Programmes like Digital India Land Records Modernization (DILRMP) and National Generic Document Registration System (NGDRS) digitise records but do not correct faulty and unclear titles.

Measures taken to improve Land Record System in India

DILRMP: It aims to replace the manual presumptive land-title system with a digital conclusive land titling system.
Initiatives under DILRMP
- Unique Land Parcel Identification Number (ULPIN) or Bhu-Aadhar: 14 digit Alpha–numeric unique ID for each land parcel based on Geo-coordinates to streamline real estate transactions, and resolve property disputes.
- NGDRS or E-Registration: It empowers citizens through online entry of deed, online payment, online appointment, online admission, document search and certified copy generation.
- Linkage of e-Court with Land Records / Registration Data base: It makes authentic first-hand information available to Courts resulting in speedy disposal of cases and reduction in land disputes.
- Transliteration of Land Records: To overcome language barrier, transliterate Records of Rights in local language to any 22 languages listed in Schedule VIII of Constitution.
Digitalise Land Record System of different States
- Dharani portal/Bhubharati portal Telangana: To modernize land administration by digitizing land records and streamlining transactions.
- Kaveri portal, Karnataka: To reform land registration.
- Banglarbhumi platform, West Bengal: To provide easy access to land and property records.

Supreme Court's Call for Systemic Reformation: Conclusive Titling and Technology

Conclusive Title: Court has directed the Law Commission of India (LCI) for creating a committee with State participation to examine and integrate property registration regime with conclusive titling.
Restructuring old laws: LCI should prepare a report on restructuring century-old colonial-era laws governing property transactions, including Transfer of Property Act (1882), Registration Act (1908), and Stamp Act (1899), to align them with modern technology.
Synchronization: Align registration with real-time land-holding records, ensure mutation records, survey and settlement operations are timely and accurate so that the registration reflects actual holding.
Regulatory Authority: Establish a permanent regulatory body for registration offices to build institutional memory and enable real-time assessment and up-gradation of the registration establishment.
Blockchain Technology based Land Titling:
- It can create a secure, transparent, tamper-proof land registration system, where each record becomes part of cryptographically linked ledger that cannot be altered without detection. Thus, enhancing integrity of title records.
  - Blockchain is a decentralized, immutable digital ledger that securely records transactions across a network of computers (nodes).
  - It organizes data into "blocks" that are cryptographically linked in a "chain," making records transparent, tamper-proof, and verifiable without a central authority like a bank or government.
- It could integrate cadastral maps, survey data and revenue records into a single, verifiable and accessible digital framework, thereby reducing fraud, improving traceability and enhancing public trust in land ownership.

Conclusion

A future-ready land governance architecture anchored in conclusive titling, harmonised laws, accurate land records and emerging technologies like blockchain, can significantly reduce disputes, enhance ease of transactions and restore public trust. Such reforms are essential not only for securing property rights but also for unlocking land's potential as a driver of economic growth, urban planning and social justice.