Allowed

Reena Kumari v. G N C T of Delhi & Ors.

Delhi HC12 Aug 2026W.P.(C)/11495/2026

Case brief

AI extract

What is this about?

The Delhi High Court directed the Sub-Registrar not to refuse registration of a sale deed concerning agricultural land solely due to pending consolidation proceedings or lack of NOC/sanction. The Court relied on precedents holding that registration cannot be indefinitely withheld, directing the petitioner to provide an undertaking which would form part of the deed pending future consolidation stat

What did the court decide?

The petition was disposed of by issuing directions that the Sale Deed shall not be refused registration solely on account of pendency of consolidation proceedings or non-availability of NOC/sanction.

Reena Kumari Vs G N C T of Delhi & Ors. — Landlord and Tenant | Delhi HC (2026)

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$~74

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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CNR No. DLHC010370052026

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- W.P.(C) 11495/2026 & CM APPL. 53216/2026

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REENA KUMARI .....Petitioner

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Through: Mr. V.P Dabas, Advocate.

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versus

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G N C T OF DELHI & ORS. .....Respondents Through: Ms. Harshita Nathrani, Advocate for Mr. Sameer Vashisht, Standing Counsel (Civil) for GNCTD.

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CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA

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O R D E R

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% 12.08.2026

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The Petitioner states that Respondent No. 3, a co-owner/co-bhumidhar in possession of unpartitioned agricultural land admeasuring 95 Bighas 12 Biswas, situated in the revenue estate of Village Ladpur, Delhi - 110081, held a 1/12^th share in the land comprised in Khasra Nos. 39//13/1 (4-12), 17/1 (2-08), 9 (4-09), 8/1 (4-12), 31//19 (4-16), 20 (4-16), 12 (4-16), 33//22/3 (0-11), 23/1 (3-16), 39//12 (6-02), 18/1 (3-12), 18/2 (1-00), 23/1 (114), 23/2 (0-12), 43//Min (4-00), 52//12 (3-17), 13//1 (2-00), 13/2 (2-16), 17 (4-16), 18/1 (2-16), 18/2 (2-00), 19 (2-00), 23 (3-14), 24 (4-16), 73//11/3 (208), 12 (4-16), 20/1 (4-05) and 21/1 (3-12). It is stated that Respondent No.3 transferred 48/1912 share, equivalent to 2 Bighas 8 Biswas, out of his 1/12^th share in the aforesaid land to the Petitioner by Sale Deed dated 15^th July,

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 14/08/2026 at 13:18:51

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2026, for a sale consideration of INR 26,50,000/-.

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It is further stated that the Sale Deed dated 15^th July, 2026 was duly presented before the concerned Sub-Registrar, and was acknowledged by issuance of acknowledgement slip. The grievance of the Petitioner is that, despite completion of the stated legal and procedural formalities, the Sale Deed has not been registered on account of the pendency of consolidation proceedings in Village Ladpur, and non-availability of a sanction/NOC from the competent authority. Aggrieved thereby, the Petitioner has approached this Court.

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Mr. Sameer Vashisht, SC (Civil) for GNCTD, fairly submit that the issue raised in the present petition is covered by the decisions of this Court in Okaya Infocom Pvt. Ltd. & Anr. v. Govt. of NCT of Delhi & Anr.¹ and subsequent orders following the same. In view of the same, Mr. Vashisht submits that, Respondents No. 1 and 2 are not insisting upon an NOC/sanction at this stage for registration of the aforesaid Sale Deed.

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Indeed, in Okaya Infocom Pvt. Ltd. , this Court held that, having regard to the prolonged nature of consolidation proceedings, registration of such documents cannot be indefinitely withheld solely on the ground of nonavailability of an NOC/sanction. The Sub-Registrar was directed to proceed in accordance with law, without insisting upon any sanction, approval, or NOC linked exclusively to consolidation proceedings.

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The aforesaid legal position has been reiterated in subsequent decisions, including in Jeevantika Organic Farming LLP v. Govt. of NCT of Delhi & Ors.² , wherein, while taking note of the stand of the

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1 In W.P.(C) 12122/2021 , decided on 10th November, 2023.

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2 In W .P. (C) 12083/2025 & other connected matters decided on 12th August, 2025.

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 14/08/2026 at 13:18:51

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Government, this Court balanced equities by requiring the intending purchaser(s) therein to furnish an undertaking. The underlying principle, namely that registration cannot be stalled indefinitely on account of pending consolidation proceedings, is equally applicable to the present case.

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For the foregoing reasons and having regard to the facts of the present case, and particularly in light of the stand taken by Respondents No. 1 and 2, this Court is of the opinion that the writ petition can be disposed of by issuing directions in similar terms.

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Accordingly, it is directed as under:

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(i) The affidavit/undertaking already placed on record by the Petitioner is taken on record and accepted. The Petitioner shall remain bound by the same.

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(ii) Any breach of the aforesaid undertaking shall entail consequences in accordance with law. The undertaking shall also form part of the Sale Deed so as to put any subsequent transferee to notice.

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(iii) Subject to verification of the land acquisition status by the competent authority, and in line with the decisions in Okaya Infocom Pvt. Ltd. , Shailender Bansal and Jeevantika Organic Farming LLP , it is directed that the registration of the Sale Deed shall not be refused solely on the ground of pendency of consolidation proceedings or non-availability of any NOC/sanction in that regard, and shall be processed further in accordance with law.

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(iv) It is clarified that the registration shall be without prejudice to the pending consolidation proceedings and shall remain subject to the rights, claims, and contentions of third parties, if any.

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With the foregoing directions, the petition, along with any pending

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 14/08/2026 at 13:18:51

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application(s), stands disposed of.

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SANJEEV NARULA, J

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AUGUST 12, 2026/ab

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This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 14/08/2026 at 13:18:51

Reena Kumari v. G N C T of Delhi & Ors.

Case brief

What is this about?

What did the court decide?

Reena Kumari v. G N C T of Delhi & Ors.

Case brief

What is this about?

What did the court decide?

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