Purchaser sought registration of a sale deed withheld by the Kanjhawala Sub-Registrar pending consolidation proceedings and a demanded NOC/LSR. Following earlier decisions, the Court directed registration to be processed without insisting on the NOC/LSR, subject to the petitioner's undertaking and third-party rights.
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MUKESH KUMAR .....Petitioner
Through: Mr. Anuroop P. S., Mr. Surinder Singh Rana and Mr. Aditya S., Advocates.
versus
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.
CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA
This is a digitally signed order.
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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.
1 In W.P.(C) 12122/2021 , decided on 10th November, 2023.
2 In W .P. (C) 12083/2025 & other connected matters decided on 12th August, 2025.
This is a digitally signed order.
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consolidation proceedings, is equally applicable to the present case.
(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.
(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.
MAY 8, 2026/ hc
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 11/05/2026 at 13:48:19
1 issue framed by the court
Whether the Sub-Registrar can refuse registration of a sale deed solely due to pendency of consolidation proceedings or non-availability of NOC/LSR for Village Kanjhawala.
Colour shows how this judgement treated each authority
Okaya Infocom Pvt. Ltd. & Anr. v. Govt. of NCT of Delhi & Anr.Relied on¶5
W.P.(C) 12122/2021, decided on 10th November, 2023
Jeevantika Organic Farming LLP v. Govt. of NCT of Delhi & Ors.Relied on¶6
W.P.(C) 12083/2025 & other connected matters decided on 12th August, 2025
Mukesh Kumar
The Govt. of NCT of Delhi
Sub-Registrar-VI D (Kanjhawala)
Sanjeev Narula
As recorded by the court registry
A petition under Article 226 of the Constitution asking a High Court to issue a writ against the State or a public authority in a civil matter.
Judgements on the same questions, provisions and authorities, from every court
