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Show 502 ADJUDICATION OF WATER RIGHTS IN WATERCOURSES In States that recognize riparian as well as appropriative rights, there are variations in the extent to which both kinds of rights may be adjudicated in special statutory adjudication proceedings. In California, it is expressly pro- vided by statute that "The [Water Resources Control Board] may determine * * * all rights to water of a stream system whether based upon appropriation, riparian right, or other basis of right."337 In Oregon, however, it has been held that one who claims a riparian right in a special statutory adjudication proceeding, but who asserts a right to a specific quantity of water with a fixed time of beginning use-which he must establish in order to have an enforceable priority-thereby claims essentially as an appropriator and waives his riparian claim for the purpose of that proceeding.338 Venue Generally speaking, the county or locality in which a suit to adjudicate water rights must be brought bears some relation to location of the lands to which the rights in litigation apply. Some judicial holdings or expressions or legislative directives on this matter follow.339 California The water right, whether appropriative or riparian, is real property. Hence an action to quiet title to such a property right must be commenced in the county in which the land to which the right is attached, or some part of it, is situated.340 Determinations made by the State Water Resources Control Board under the statutory adjudication procedures are to be filed in the superior court of the county in which the stream system or some part thereof is situated.341 Colorado Jurisdiction to adjudicate water matters arising in each water division is vested exclusively in the district courts of all of the counties or portions thereof situated in the division, acting collectively through the water judge in that division.342 and its downgrading or outright repudiation in others, and a summary of recognition, repudiation, and status in individual Western States. 337Cal. Water Code § 2501 (West Supp. 1970). 338See the discussion in chapter 10 at notes 509-515. 39 For some related considerations, see "Jurisdiction-Stream Crossing State Line," infra. ^"Miller & Lux v. Modem anal & In. Co., 155 Cal. 59, 73, 99 Pac. 502 (1907), construing Cal. Const, art. VI, § 5. This may be any county in which any part of such land is situated. Sutter-Butte Canal Co. v. Great Western Power Co. of California, 65 Cal. App. 597, 599-600, 224 Pac. 768 (1924). 341 Cal. Water Code § 2750 (West Supp. 1970). 342Colo. Rev. Stat. Ann. § 148-21-10(1) (Supp. 1969). Section 148-21-8 establishes the |