Disposed¶70

Adi Ramachandra Rao, v. The State of Andhra Pradesh

Andhra Pradesh HC5 Jan 2026WA/7/2026

Case brief

AI extract

What is this about?

Sub-Registrar; refusal of registration; Section 22-C Registration Act 1908; property already sold by executant; title dispute outside registering authority's jurisdiction; prima facie title verification; remedy before civil court; Jangareddygudem; R.S.No.323/2A; sale deed dated 19.01.1985 document No.137/1985; W.P.No.27909 of 2025 dismissed 21.11.2025; W.P.No.403 of 2024 order dated 25.04.2024; Muppidi Mangamma; Sub Registrar Chintalapudi; Eluru District; writ appeal disposed with liberty.

What did the court decide?

Writ Appeal disposed of with liberty left to the appellants to pursue all their remedies in law; no order as to costs; pending miscellaneous applications closed. ¶70

Adi Ramachandra Rao, Vs The State of Andhra Pradesh — Andhra Pradesh HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Writ Appeal disposed of with liberty left to the appellants to pursue all their remedies in law; no order as to costs; pending miscellaneous applications closed.

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Issue for consideration

Whether Section 22-C of the Registration Act, 1908 casts a duty on the Registering Authorities to refuse registration of documents purporting to sell immovable property already sold by the executant. +1 more

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Court's answer

Section 22-C of the Registration Act, 1908 does not extend to the Sub-Registrar refusing registration of documents of alienation executed by a person who had already sold the property to third parties.

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Ratio / Principle

It is not within the jurisdiction of the Sub-Registrar to go into questions of title and decide whether documents presented for registration can be refused on the ground of a dispute on title.

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Key takeaways

The Registering Authority is nonetheless required to examine prima facie title and verify whether the provisions of the Act and Rules are being complied with.ratio¶68
The appropriate course for the appellants is to approach a competent court of civil jurisdiction for their remedies against the 7th respondent and her proposed alienation of the land already sold.ratio¶69
While considering any documents produced by the 7th respondent, the Sub-Registrar shall act strictly in accordance with law.

Detailed headnote1 paragraphs

High Court of Andhra Pradesh at Amaravati (Division Bench; per R. Raghunandan Rao, J), Writ Appeal No. 7 of 2026, decided 06.01.2026 — Registration — Section 22-C, Registration Act, 1908 — Duty to refuse registration — Section 22-C does not require the Sub-Registrar to refuse registration of a document of alienation on the ground that the executant had already sold the property to third parties; the Sub-Registrar has no jurisdiction to decide questions of title or refuse registration on the ground of a title dispute, though the Registering Authority must still examine prima facie title and verify compliance with the Act and Rules. Purchasers claiming under an earlier sale who object to a subsequent alienation must seek redress before a competent court of civil jurisdiction. Writ Appeal against dismissal of W.P.No.27909 of 2025 (which had sought a direction to the Sub-Registrar to refuse registration of documents presented by the 7th respondent) disposed of, with liberty to the appellants to pursue their remedies in law and a direction that the Sub-Registrar act strictly in accordance with law while considering documents produced by the 7th respondent. No order as to costs; pending miscellaneous applications closed.

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[3529]

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APHC010723712025

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IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI

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(Special Original Jurisdiction)

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TUESDAY, THE SIXTH DAY OF JANUARY TWO THOUSAND AND TWENTY SIX

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PRESENT

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THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO

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THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR

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WRIT APPEAL NO: 7/2026

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Writ Appeal under clause 15 of the Letters Patent to set-aside the Order, dt. 21.11.2025 passed in WP. No. 27909 of 2025 and consequently allow the Writ Appeal and pass

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Between:

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ADI RAMACHANDRA RAO,, S/O. ADI VEERA VENKATA RAO, AGED 41 YEARS, OCC. BUSINESS, R/O H. NO. 29-62, SRINIVAS PURAM ROAD, OPP. GOVERNMENT DEGREE COLLEGE JANGAREDDYGUDEM MANDAL, ELURU DISTRICT (ERSTWHILEWEST GODAVARI DISTRICT).

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M. RAMADEVI,, W/O. MUTYALA RAO, AGED 40 YEARS OCC. CULTIVATION, R/O. NEAR BYPASS ROAD, JANGAREDDYGUDEM, ELURU DISTRICT.

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B. SIMHACHALAM,, S/O. TAVITI NAIDU, AGED 59 YEARS, OCC. CULTIVATION, R/O. NEAR CHINTALA BAZAR, JANGAREDDYGUDEM, ELURU DISTRICT.

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M.N.R.V. PRASAD, , S/O, M. VEERA BHADRUDU, AGED 62 YEARS, R/O. 410-68/A/I, VENKATA SAI NAGAR COLONY, LANE NO. 10, CHENGICHERLA, PEERZADIQUDA, UPPAL POST, MEDCHAL MALKAJIGIRI DISTRICT, TELANGANA STATE - 500039.

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M. SRINIVASULU,, S/O. LATE PENTAIAH, AGED 40 YEARS, OCC. CULTIVATION, R/O. JANGAREDDYGUDEM VILLAGE AND MANDAL, ELURU DISTRICT (FORMERLY WEST GODAVARI DISTRICT).

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RRR,J & TCDS,J

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W.A.No.7 of 2026

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Y. VEERABHADRAM,, S/O. SUBBA RAIDU, AGED 45 YEARS, OCC. CULTIVATION, R/O. JANGAREDDYGUDEM VILLAGE AND MANDAL, ELURU DISTRICT (FORMERLY WEST GODAVARI DISTRICT).

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A. NAGESWARA RAO,, S/O. NIRANJAN RAO, AGED 55 YEARS, OCC. CULTIVATION, R/O. JANGAREDDYGUDEM VILLAGE AND MANDAL, ELURU DISTRICT (FORMERLY WEST GODAVARI DISTRICT)

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T. PRASAD,, S/O. PARASU RAMUDU, AGED 45 YEARS OCC. CULTIVATION, R/O. GANAPAVARAM VILLAGE, BUTTAYYAGUDEM, ELURU DISTRICT.

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K. LEELAVATHI,, W/O. LAKSHMAN RAO, AGED 75 YEARS OCC. CULTIVATION, R/O. KOWURU ROAD, JANGAREDDYGUDEM, ELURU DISTRICT.

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T. SUBBA LAKSHMI,, W/O. SURYA CHANDRA RAO, AGED 56 YEARS, OCC. CULTIVATION, R/O. SWAMA VARI GRAMAM, JILLUGUMILLI MANDAL ELURU DISTRICT

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Y. VIJAYALAKSHMI,, W/O. SATYANARAYANA, AGED 45 YEARS, OCC. CULTIVATION, R/O. JANGAREDDYGUDEM VILLAGE AND MANDAL, ELURU- DISTRICT (FORMERLY WEST GODAVARI DISTRICT).

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K. CHIRANJEEVI RAJU,, S/O. LATE RAMAKRISHNAM RAJU AGED 53 YEARS, R/O. D.NO.29-138, NEAR BYPASS, JANGAREDDYGUDEM VILLAGE AND MANDAL, ELURU DISTRICT (FORMERLY WEST GODAVARI DISTRICT).

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...APPELLANT(S)

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AND

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THE STATE OF ANDHRA PRADESH, REP.BY ITS PRINCIPAL SECRETARY, REVENUE (STAMPS AND REGISTRATION), DEPARTMENT, SECRETARIAT, VELAGAPUDI, AMARAVATI, GUNTUR DISTRICT - 522238.

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THE DISTRICT COLLECTOR, ELURU DISTRICT AT ELURU FORMERLY WEST GODAVARI DISTRICT - 534006.

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RRR,J & TCDS,J W.A.No.7 of 2026

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THE DISTRICT REGISTRAR, (STAMPS AND REGISTRATION), AMEENAPET, ELURU TOWN AND MANDA, ELURU DISTRICT - 534006.

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THE DISTRICT LEVEL COMMITTEE, REP.BY COLLECTOR, ELURU DISTRICT AT ELURU - 534006.

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THE TAHSILDAR, JANGAREDDYGUDEM MANDAL, ELURU DISTRICT - 534447.

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THE SUB REGISTRAR, (STAMPS AND REGISTRATION), CHINTALAPUDI, ELURU DISTRICT - 5344Q0.

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MUPPIDI MANGAMMA, W/O. LATE NAGAIAH, AGE 64 YEARS, R/O.H.NO.1-1-174, JAGAJEEVANNAGAR, JANGAREDDYGUDEM MANDAL, ELURU DISTRICT, ERSTWHILE WEST GODAVARI DISTRICT - 534447

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...RESPONDENT(S):

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IA NO: 1 OF 2026

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Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased to dispense with filing of Certified Copy of Order Dt. 21.112025 passed in W.P No. 27909 of 2025 on the file of this Hon’ble Court and to receive the main Writ Appeal on file, by accepting a copy thereof downloaded from the Official Website of this Hon’ble Court in the interests of justice pass

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IA NO: 2 OF 2026

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Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased to condone the delay of 9] days in filing the present Writ Appeal against an Order Dt. 21.11.2025 passed in W.P No. 27909 of 2025 and to receive the Writ Appeal on file in the interests of justice and to pass

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IA NO: 3 OF 2026

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Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased to suspend the operation of the Order, dt. 21.11.2025 passed in WP. No. 27909 of 2025 and consequentially direct the respondents 2 to 6 particularly 6^'" respondent not to entertain registration of any deed of conveyance connected to appellants properties covered by R.Sy. No. 323/2A

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RRR,J & TCDS,J W.A.No.7 of 2026

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of Jangareddygudem Revenue Village and Mandal, Eluru District, if executed and presented by 7th respondent, pending disposal of the main Writ Appeal and to pass

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Counsel for the Appellant(S):

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1.PALA KARTHI KIRAN

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Counsel for the Respondent(S):

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1.GP FOR REVENUE

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2.GP FOR REGISTRATION AND STAMPS

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RRR,J & TCDS,J W.A.No.7 of 2026

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The Court made the following Judgment:

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(per Hon’ble Sri Justice R. Raghunandan Rao)

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The 7^th respondent is said to have executed a deed of sale, dated 19.01.1985, registered as document No.137/1985 in favour of one Sri P. Subramanyam. The contention of the appellants is that, the 7^th respondent, who was the owner of Ac.2.80 cents of land, in R.S.No.323/2A of Jangareddygudem Village and Mandal, Eluru District, had made a layout of the land and sold the plots therein to one Sri P. Subramanyam, by a deed of sale, and the late Sri P. Subramanyam is said to have sold 12 plots to the appellants herein.

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The appellants, approached the Sub-Registrar, Chintalapudi, who is arrayed as the 6^th respondent, with the complaint that, the 7^th respondent was trying to alienate and to sell the very same land to the third parties, despite the fact that, she had already sold away the land to late Sri P. Subramanyam, and had no right and title over the same property.

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The appellants, had thereafter, approached this Court, by way of W.P.No.27909 of 2025, contending that, the Sub-Registrar, was refusing to look into their objections and seeking a direction to the Sub-Registrar to refuse registration of documents, in relation to the aforesaid survey number, presented either by the 7^th respondent or any agent or person submitted on her behalf. A learned Single Judge of this Court, by a Judgment, dated 21.11.2025, had dismissed the Writ Petition, on the ground that, such a direction, cannot be given to the Sub-Registrar, and it would only be

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RRR,J & TCDS,J W.A.No.7 of 2026

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appropriate that, the appellants approach a Civil Court for redressal of their disputes.

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Aggrieved by this Judgment, the appellants have approached this Court, by way of the present Writ Appeal.

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Sri P. Karthi Kiran, learned counsel appearing for the appellants, would contend that, Section 22-C of the Registration Act, 1908, requires the Registering Authorities to refuse registration of documents, which purport to sell immovable property, which had already been sold by the executant. The learned counsel would submit that, in such circumstances, there is a duty cast, on the Sub-Registrar, to refuse registration of any documents, executed by the 7^th respondent and any agent or person claiming through her. The learned counsel would also contend that, the 7^th respondent, had earlier approached this Court, by way of W.P.No.403 of 2024, with the complaint that, the documents being presented by her, were not being accepted by the Sub-Registrar. A learned Single Judge, by a Judgment, dated 25.04.2024, had directed the Sub-Registrar to consider any document presented by the 7^th respondent, in accordance with Law. The learned counsel apprehends that this Order would tie the hands of the Sub-Registrar.

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A perusal of Section 22-C of the Registration Act, 1908, would show that, the said provision does not extend to the Sub-Registrar refusing registration of documents of alienation executed by a person, if such a person had already sold the property to the third properties. Further, it would not be

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RRR,J & TCDS,J W.A.No.7 of 2026

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within the jurisdiction of the Sub-Registrar to go into the questions of title and decide whether documents presented for registration can be refused, on the ground of dispute on title. However, the Registering Authority would still be required to go into prima facie title and to verify whether the provisions of the Act and Rules are being complied or not.

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As held by the learned Single Judge, the appropriate course of action for the appellants would be to approach a Competent Court of Civil Jurisdiction for seeking their remedies against the 7^th respondent and her proposed action of alienating the land, which has already been sold.

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In these circumstances, this Writ Appeal is disposed of, leaving it open to the appellants to file all their remedies in Law.

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Needless to say, the Sub-Registrar would act strictly in accordance with Law, while considering any documents produced by the 7^th respondent. There shall be no order as to costs.

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As a sequel, pending miscellaneous applications, if any, shall stand closed.

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