D N VENKATARAYAPPA vs STATE OF KARNATAKA — C.A. No. 1943/2002

Case Summary: D.N. Venkatarayappa v. State of Karnataka Case No.: SLP(C) No. 11167 of 1997 (with 29 connected matters) Heard: 30 January 2002 Bench: Justices G.B. Pattanaik, S.N. Phukan, Brijesh Kumar Outcome: The three-judge bench found no inconsistency among four earlier Supreme Court decisions interpreting the Karnataka Scheduled Castes and Scheduled Tribes (Prohibition of Transfer of Certain Lands) Act, 1978. The court clarified that whether a transferee can acquire title by adverse possession depends on whether the original grantee held absolute title or merely a right of enjoyment—a determination requiring examination of the grant itself. If absolute title was granted, the prescriptive period is 12 years; if only usufruct rights, 30 years. Direction: The entire batch of cases was remitted to an appropriate two-judge bench for merit-based determination on the basis of established facts. This case analysis is maintained by casestatus.in based on publicly available court records.