The Supreme Court of India held that mutation of revenue records can be carried out on the basis of a will, clarifying the limited scope of mutation proceedings. In Tara Chandra v. Bhawarlal & Anr., the dispute concerned mutation based on a registered will executed by the deceased tenure holder. While revenue authorities allowed mutation on this basis, the High Court set aside the order, relying on an earlier view that mutation could not be founded on a will. Reversing the High Court, the Supreme Court held that neither the M.P. Land Revenue Code, 1959 nor the 2018 Rules prohibit mutation based on a will. A Tehsildar cannot reject such an application merely because the claim flows from a testamentary instrument. The Court reiterated that mutation is a summary, administrative process for fiscal purposes and does not determine title, which must be adjudicated by a civil court if seriously disputed. As no legal heir challenged the will and the opposing claim rested on an unregistered agreement, the mutation order was rightly passed. The appeal was allowed, restoring the mutation, subject to civil proceedings.