The Supreme Court held that a revenue entry recording land as held for religious or charitable purposes does not by itself prove a completed dedication or determine the nature of possession. It also ruled that long, uninterrupted possession is not adverse possession unless the possessor proves hostile intent, openly asserted against the true owner and to the owner's knowledge.
What this changes for a title check
A Jamabandi or Khasra Girdawari entry naming who is "in possession" is evidence of possession, not proof of ownership or of a completed gift or dedication; a title check that stops at the revenue record and treats it as settling ownership is reading it for more than it can bear. A party claiming a religious or charitable dedication now has to show a clear, unequivocal act by the owner giving up title, not just a longstanding revenue entry describing the purpose of possession. Equally, decades of physical possession is not enough on its own to defeat a registered sale deed: the possessor has to point to a specific moment their possession turned hostile to the recorded owner, and to some overt act that put the owner on notice of that hostility. For a report flagging "long possession by a third party" as a title risk, the follow-up question is now sharper: was there ever an assertion of hostile ownership, or just quiet occupation.