Preeti & Anr. v. Gnct of Delhi & Ors.

Delhi HC7 Apr 2026W.P.(C)/4564/2026

Case brief

AI extract

What is this about?

Village Ladpur agricultural land; consolidation proceedings; NOC/Land Status Report (LSR); Deficiency Memo 02.12.2022; Sub-Registrar VI-D; Sale Deed 25.11.2022; Special Power of Attorney; mutation; Okaya Infocom W.P.(C) 12122/2021; Jeevantika Organic Farming W.P.(C) 12083/2025; registration directions; undertaking; GNCTD; W.P.(C) 4564/2026.

What did the court decide?

Petition disposed of with directions that registration of the Sale Deed dated 25.11.2022 and the Special Power of Attorney of even date shall not be refused solely on the ground of pendency of consolidation proceedings or non-availability of NOC; Petitioners' undertaking accepted and to form part of the registered Sale Deed; subject to verification of land acquisition status, without prejudice to consolidation proceedings and third-party rights. ¶¶24

Preeti & Anr. Vs Gnct of Delhi & Ors. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

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Issue for consideration

Whether registration of the Sale Deed dated 25.11.2022 and the accompanying Special Power of Attorney can be refused or withheld solely because consolidation proceedings are pending in Village Ladpur and consequently no NOC/LSR for the agricultural land is being issued.

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Court's answer

Registration of the Sale Deed dated 25th November, 2022 and the Special Power of Attorney of even date 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, subject to verification of the land acquisition status by the competent authority.

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Ratio / Principle

The affidavit/undertaking already placed on record by the Petitioners (in terms of the judgment in Okaya Infocom Pvt. Ltd.) is taken on record and accepted, and the Petitioners shall remain bound by the same.

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Key takeaways

Any breach of the undertaking shall entail consequences in accordance with law, and the undertaking shall form part of the registered Sale Deed so as to put any subsequent transferee to notice.ratio¶¶22
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.ratio¶¶23

Detailed headnote1 paragraphs

Writ petition by purchasers (Preeti & Anr.) of a 1/72 share of agricultural land in Village Ladpur, Delhi, whose Sale Deed dated 25.11.2022 and companion Special Power of Attorney, presented before Sub-Registrar VI-D, were stalled by a Deficiency Memo dated 02.12.2022 demanding an NOC/Land Status Report owing to pending consolidation proceedings. Relying on its own decisions in Okaya Infocom Pvt. Ltd. (W.P.(C) 12122/2021) and Jeevantika Organic Farming LLP (W.P.(C) 12083/2025), the Court disposed of the petition: the Petitioners' undertaking was accepted (to be embedded in the registered deed, breach entailing legal consequences) and it was directed that registration shall not be refused solely for pendency of consolidation proceedings or non-availability of NOC, subject to verification of land acquisition status, without prejudice to the consolidation proceedings and to third-party rights.

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$~98

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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W.P.(C) 4564/2026, CM APPL. 22240/2026 PREETI & ANR. .....Petitioners Through: Mr. V.P. Dabas, Mr. Bharat Thakur, Mr. Vineet Dabas, Mr. Raj Kumar Dabas and Ms. Kirandeep Kaur, Advocates.

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versus GNCT OF DELHI & ORS. .....Respondents Through: Ms. Avni Singh, Panel Counsel for GNCTD with Mr. Vaibhav Sharma, Advocate.

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CORAM:

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HON'BLE MR. JUSTICE SANJEEV NARULA

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O R D E R

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% 07.04.2026 1. The Petitioner No. 1 is the purchaser of land measuring 1/72 share out of agricultural land measuring 73 bighas 10 biswas comprised in Khasra Nos. 29//16/2 (4-13), 15/2 (1-13), 30//11 (4-16), 20 (4-16), 45//17 (4-16), 18 (4-16), 23 (4-16), 24 (4-16), 47//12 (4-16), 19/1 (4-11), 19/2 (0-05), 9 (416), 58//15 (4-16), 6 (4-16), 65/3 (4-16), 4 (4-16) and 72//18 (4-16), situated in the revenue estate of Village Ladpur, Delhi – 110081.

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Respondent No. 4 (vendor), being the recorded co-owner, executed and presented a Sale Deed dated 25^th November, 2022 in favour of Petitioner No. 1 for the aforesaid share. The said Sale Deed, along with a Special Power of Attorney dated 25^th November, 2022 executed in favour of Petitioner No. 2 for purposes of mutation, was presented for registration before Respondent No. 3 (Sub-Registrar VI-D).

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At the time of presentation, the Petitioners were required to furnish NOC/Land Status Report (“LSR”) in respect of the subject land. A

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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 09/04/2026 at 13:12:44

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Deficiency Memo dated 2^nd December, 2022 was accordingly issued by Respondent No. 3, recording that NOC for agricultural land was required and calling upon the Petitioners to remove the deficiency within the stipulated period for further processing of the documents.

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The Petitioners contend that the insistence on NOC/LSR is untenable, particularly when no such NOC is being issued in respect of lands situated in Village Ladpur on account of pendency of consolidation proceedings. 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 has 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. 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 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

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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 09/04/2026 at 13:12:44

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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 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.

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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. (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 dated 25^th November, 2022 and the Special Power of Attorney of even date 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.

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

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SANJEEV NARULA, J

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APRIL 7, 2026/ nk

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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 09/04/2026 at 13:12:44

Preeti & Anr. v. Gnct of Delhi & Ors.

Case brief

What is this about?

What did the court decide?

Preeti & Anr. v. Gnct of Delhi & Ors.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

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