Disposed

Krishan Kumar v. Govt of NCT of Delhi & Ors.

Delhi HC25 Feb 2026W.P.(C)/2619/2026

Case brief

AI extract

What is this about?

A petitioner purchased agricultural land in Village Ladpur, Delhi, where registration was withheld due to pending consolidation proceedings. Relying on precedent, the Court held that registration cannot be indefinitely stalled on this ground. It directed the Sub-Registrar to process the registration subject to the petitioner filing an undertaking to disclose the order's factum in future transactio

What did the court decide?

Registration directed subject to filing of undertaking; petition disposed of.

Krishan Kumar Vs Govt of NCT of Delhi & Ors. — Land Acquisition | Delhi HC (2026)

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$~87

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 2619/2026 & CM APPL. 12745/2026 (Exemption)

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KRISHAN KUMAR .....Petitioner

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Through: Mr. Rahul Sharma, Mr. Surender, Mr. Yash Tokas, Advocates.

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versus

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GOVT OF NCT OF DELHI & ORS. .....Respondents Through: Mr. Lalltaksh Joshi, Ms. Minu Kumari, Advocates for GNCTD. Mr. Sanjay Kumar Pathak, Standing Counsel with Mrs. K. Kaomudi Kiran Pathak, Mr. Sunil Kumar Jha, Mr. M.S. Akhtar, Ms. Joohu Kumari, Advocates for LAC.

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CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA

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O R D E R

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% 25.02.2026

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The Petitioner is the purchaser of 1/72 share in agricultural land measuring 95 Bigha 12 Biswa 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//3 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), situated in the revenue estate of Village Ladpur, Delhi – 110081.

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Respondent No. 4 (vendor), being one of the legal heirs of late Mr.

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W.P.(C) 2619/2026 Page 1 of 4

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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 26/02/2026 at 13:23:43

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Jeet Ram, executed a Sale Deed dated 03^rd June, 2025, in favour of the Petitioner for the aforesaid share. The Sale Deed was presented for registration before Respondent No. 2 (Sub-Registrar VI-D).

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At the time of presentation, the Petitioner was directed to obtain NOC/Land Status Report (“ LSR ”) from Respondents No. 1 and 3. The Petitioner accordingly applied for NOC/LSR on 03^rd June, 2025. However, a Deficiency Memo dated 09^th June, 2025 was issued by the Sub-Registrar requiring production of the said NOC/LSR. 4. The application for NOC/LSR was subsequently reflected on the portal as “ Not Recommended ”, with the reason recorded as: “ Village Ladpur notified under Consolidation vide Notification dated 10.09.1993 and Consolidation Proceeding Not Completed. Hence, Not Recommended ”. 5. Counsel for the Respondents submits that since consolidation proceedings are pending in Village Ladpur, the Sub-Registrar cannot proceed with registration without requisite sanction. 6. Insofar as insistence on sanction/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 , while dealing with the registration of sale deeds, 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.

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The aforesaid legal position has been reiterated in subsequent

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W.P.(C) 2619/2026 Page 2 of 4

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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 26/02/2026 at 13:23:43

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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.

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In view of the aforesaid legal position, and having regard to the facts of the present case, this Court is of the opinion that the writ petition can be disposed of by issuing directions in similar terms. 9. Accordingly, it is directed as under: (i) The Petitioner shall file an undertaking by way of an affidavit stating that the factum of this order shall be disclosed in the event of any further transaction relating to the subject land, prior to the conclusion of the consolidation proceedings. Let the said undertaking be filed within a period of two weeks from today. Upon filing of such an undertaking, the Petitioner shall remain bound thereby.

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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 registered 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. 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

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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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W.P.(C) 2619/2026 Page 3 of 4

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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 26/02/2026 at 13:23:43

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

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SANJEEV NARULA, J

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FEBRUARY 25, 2026/ab

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W.P.(C) 2619/2026 Page 4 of 4

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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 26/02/2026 at 13:23:43

Krishan Kumar v. Govt of NCT of Delhi & Ors.

Case brief

What is this about?

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Krishan Kumar v. Govt of NCT of Delhi & Ors.

Case brief

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