Disposed

Sushma v. the Govt. of NCT of Delhi and Anr.

Delhi HC8 May 2026W.P.(C)/6284/2026

Case brief

AI extract

What is this about?

Purchaser sought writ directions as the Sub-Registrar withheld registration of a sale deed pending consolidation proceedings and insisted on an NOC/LSR. Court accepted the purchaser's undertaking, directed registration not be refused on those grounds, subject to third-party rights and consolidation proceedings.

What did the court decide?

Directions issued that registration of the sale deed shall not be refused solely on pendency of consolidation proceedings or absence of NOC/LSR; petitioner's undertaking accepted.

Sushma Vs the Govt. of NCT of Delhi and Anr. — Landlord and Tenant | Delhi HC (2026)

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$~60

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 6284/2026 & CM APPL. 30892/2026 SUSHMA .....Petitioner Through: Mr. Anuroop P. S., Mr. Surinder Singh Rana and Mr. Aditya S., Advocates.

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versus

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THE GOVT. OF NCT OF DELHI AND ANR .....Respondents Through: Mr. Dinesh Malik, Panel Counsel, GNCTD for R-1 and R-2. Mr. Sanjay Kumar Pathak, SC with Mr. Sunil Kumar Jha, Mr. M. S. Akhtar, Ms. Joohu Kumari and Mr. Kushagra Dixit, Advocates.

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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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% 08.05.2026 1. The Petitioner is purchaser of land admeasuring 2 Bigha 19 Biswas, out of total land measuring 69 Bigha 15 Biswas, comprised in Khasra Nos. 18//4 (4-16), 5 (4-16), 6 (4-16), 7 (4-16), 14 (4-16), 17 West (1-18), 17//1 (4-11), 43//19 (3-05), 43//23 (3-03), 44//3 (2-17), 8 (3-01), 82//23 (4-16), 83//3 (3-11), 17//9 (4-07), 62//9 (4-12), 66//4 (4-16), 66//10 Min (1-01), 64//25 Min (0-09), 66//13 (0-08), 66//14 (2-00), and 66//15 (1-00), situated in the revenue estate of Village Kanjhawala, Delhi.

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It is stated that Mohit S/o Late Mr. Surender, acting through his duly constituted attorney, namely Mr. Sudhir Raj Dabas, executed a Sale Deed dated 23^rd April, 2026 in favour of the Petitioner in respect of the subject land.

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The Petitioner states that the aforesaid Sale Deed was presented before Respondent No. 2, i.e., Sub-Registrar-VI D (Kanjhawala), for

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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 11/05/2026 at 13:48:20

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registration on 23^rd April, 2026, and a receipt/slip was issued acknowledging presentation of the document. However, the registration has not been processed further on account of insistence upon a No Objection Certificate [“ NOC ”] / Land Status Report [“ LSR ”], purportedly on the ground that Village Kanjhawala is under consolidation proceedings. Aggrieved thereby, the Petitioner has invoked the writ jurisdiction of this Court.

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Mr. Dinesh Malik, panel counsel for Respondents No. 1 and 2, on instructions from the office of the Sub-Registrar, VI-D (Kanjhawala), submits that, in light of the circular dated 14^th August, 2025 issued by the Office of the Divisional Commissioner, GNCTD, NOC/LSR is not being insisted upon. 5. Be that as it may, insofar as insistence on an NOC/LSR 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.

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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,

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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 11/05/2026 at 13:48:20

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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.

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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. 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/LSR 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, along with any pending application(s), in the above terms.

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SANJEEV NARULA, J

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MAY 8, 2026/ hc

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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 11/05/2026 at 13:48:20

Sushma v. the Govt. of NCT of Delhi and Anr.

Case brief

What is this about?

What did the court decide?

Sushma v. the Govt. of NCT of Delhi and Anr.

Case brief

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