Allowed

Karan Garg & Ors. v. Govt of N C T of Delhi & Ors.

Delhi HC16 Apr 2026W.P.(C)/17671/2025

Case brief

AI extract

What is this about?

The Court set aside the Sub-Registrar's refusal to register a sale deed solely on grounds of pending consolidation proceedings and non-availability of an NOC. Relying on precedent, the Court directed registration subject to verification and an undertaking by purchasers.

What did the court decide?

Refusal order dated 25.02.2025 set aside; Sub-Registrar directed to register sale deed subject to verification and undertaking.

Karan Garg & Ors. Vs Govt of N C T of Delhi & Ors. — Land Acquisition | Delhi HC (2026)

¶1

$~12

¶2

IN THE HIGH COURT OF DELHI AT NEW DELHI

¶3

- W.P.(C) 17671/2025 & CM APPL. 72996/2025 KARAN GARG & ORS. .....Petitioners

¶4

Through: Mr. Jai Narayan and Mr. V.P. Dabas, Advocates.

¶5

versus

¶6

GOVT OF N C T OF DELHI & ORS. .....Respondents Through: Ms. Avni Singh, Panel counsel (GNCTD) with Mr. Abhishek Yadav, Advocate for GNCTD.

¶7

CORAM:

¶8

HON'BLE MR. JUSTICE SANJEEV NARULA

¶9

O R D E R

¶10

% 16.04.2026

¶11

The present petition has been filed by the purchasers of the subject land, namely the Petitioners, in respect of agricultural land admeasuring 4 Bigha 14 Biswa, comprised in Khasra Nos. 75//8 (3-08) (South) and 75//13 (1-06) (North), situated in the revenue estate of Village Kanjhawala, Delhi.

¶12

It is stated that the recorded owner, through her duly constituted attorney (proforma Respondent No. 4), agreed to transfer the subject land to the Petitioners for valuable consideration. Pursuant thereto, a Sale Deed dated 19^th February, 2025 was duly executed and presented for registration before Respondent No. 3, i.e., the concerned Sub-Registrar at Kanjhawala. However, by way of refusal order dated 25^th February, 2025, the SubRegistrar declined registration of the said Sale Deed.

¶13

The refusal is premised on the ground that, in view of an order dated 05^th December, 2019 issued by the District Magistrate (North-West) to

¶14

This is a digitally signed order.

¶15

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 20/04/2026 at 15:42:40

¶16

expedite consolidation proceedings and consign the scheme (Basta Band) in Village Kanjhawala, registration of such documents has been withheld. On this basis, the Sub-Registrar declined registration of the Sale Deed. Aggrieved thereby, the Petitioner has invoked the writ jurisdiction of this Court.

¶17

Counsel for the Respondents submits that the subject land is stated to be under consolidation proceedings, and therefore, processing of the document requires permission and verification from the competent authority. 5. Insofar as insistence on NOC on account of pending consolidation proceedings is concerned, this Court in Okaya Infocom Pvt. Ltd. & Anr. v. Govt. of NCT of Delhi & Anr.¹ , held that having regard to the prolonged nature of consolidation proceedings, registration of such documents cannot be indefinitely withheld solely on the ground of non-availability of an NOC. The Sub-Registrar was directed to proceed in accordance with law, without insisting upon any sanction, approval, or NOC linked exclusively to consolidation proceedings.

¶18

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 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.

¶19

In view of the aforesaid legal position, and having regard to the facts

¶20

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

¶21

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

¶22

This is a digitally signed order.

¶23

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 20/04/2026 at 15:42:40

¶24

of the present case, this Court finds that the refusal order, being founded solely on the pendency of consolidation proceedings and the administrative circular in that regard, cannot be sustained in law. Accordingly, the refusal order dated 25^th February, 2025 is set aside, and the following directions are issued:

¶25

(i) The affidavit/undertaking already placed on record by the Petitioners, in terms of the judgment of this Court in Okaya Infocom Pvt. Ltd. , is taken on record and accepted. The Petitioners shall remain bound by the same. (ii) Any breach of the aforesaid undertaking(s) shall entail consequences in accordance with law. The undertaking(s) shall also form part of the Sale Deed so as to put any subsequent transferee to notice.

¶26

(iii) Subject to verification of the land acquisition status by the competent authority, and in line with the decisions in Okaya Infocom Pvt. Ltd. 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 in that regard, and shall be processed further in accordance with law.

¶27

(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.

¶28

In the above terms, the petition is disposed of, along with any pending application(s).

¶29

SANJEEV NARULA, J

¶30

APRIL 16, 2026 /as

¶31

This is a digitally signed order.

¶32

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 20/04/2026 at 15:42:40

Karan Garg & Ors. v. Govt of N C T of Delhi & Ors.

Case brief

What is this about?

What did the court decide?

Karan Garg & Ors. v. Govt of N C T of Delhi & Ors.

Case brief

What is this about?

What did the court decide?

What the court decided

A compact analysis

Issues for consideration

Cases cited

Parties & counsel

Coram

Case details

Similar cases

Onkar Raju Lamdade and Ors. Vs National Board of Examination in Medical Science and Ors.

Telecommunications Consultants India Limited Vs Union of India & Ors.

Seth Umashankar Agarwal Vs Union of India & Ors.

Chamma Kushwaha Vs Government NCT of Delhi & Ors.

Kunwer Sachdev Vs Union of India and Ors.

M/S Lvirgo Pharma Vs Commissioner of Cgst & Anr.

Shivani Priyam & Anr. Vs Union of India & Anr.

Municipal Corporation of Delhi & Anr. Vs Raju

Mahadev Singh Sen Vs Institue of Human Behaviour Science and Allied Science and Ors.

Babu Lal Koli Vs United India Insurance Co. Ltd.

Samrita Singh Vs Bank of India & Ors.

Ashok Kumar Vs Gnctd & Ors.

Ram Ratan Verma and Ors. Vs the Union of India and Ors.

Pratibha Dagar & Anr. Vs Govt of N C T of Delhi & Ors.