Disposed¶29

Jatin Garg v. the Govt of NCT of Delhi and Anr.

Delhi HC12 May 2026W.P.(C)/6458/2026

Case brief

AI extract

What is this about?

Release deed registration refused for pending consolidation proceedings; NOC/LSR insistence; Sub-Registrar-VI D Kanjhawala; Village Kanjhawala Khasra No. 50//2 min; GNCTD; undertaking embedded in sale deed; land acquisition status verification; Okaya Infocom Pvt. Ltd.; Jeevantika Organic Farming LLP; registration cannot be stalled indefinitely; Delhi High Court writ petition disposed with directions.

What did the court decide?

Petition disposed of with directions that registration of the Sale Deed not be refused solely for pendency of consolidation proceedings or non-availability of NOC/LSR, subject to the Petitioner's accepted undertaking (to form part of the Sale Deed), verification of land acquisition status by the competent authority, and without prejudice to pending consolidation proceedings and third-party rights. ¶29

Jatin Garg Vs the Govt of NCT of Delhi and Anr. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

¶29

Issue for consideration

Whether registration of the Petitioner's document (Sale Deed arising out of the Release Deed) can be refused solely on account of pendency of consolidation proceedings in Village Kanjhawala and the consequent insistence on an NOC/LSR.

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Court's answer

The underlying principle that registration cannot be stalled indefinitely on account of pending consolidation proceedings is equally applicable to the present case.

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Ratio / Principle

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; it shall be processed further in accordance with law, 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.

¶27

Key takeaways

The Petitioner's affidavit/undertaking placed on record is accepted and binding; any breach shall entail consequences in accordance with law, and the undertaking shall form part of the Sale Deed so as to put any subsequent transferee to notice.ratio¶26
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¶28

Detailed headnote1 paragraphs

Delhi High Court (Sanjeev Narula, J) disposed of a writ petition concerning registration of a Release Deed dated 01.12.2025 (executed by recorded co-owner Rakesh Jain in favour of the petitioner) over land in Village Kanjhawala, which the Sub-Registrar-VI D declined to complete absent an NOC/LSR owing to pending consolidation proceedings. Relying on its earlier decisions in Okaya Infocom Pvt. Ltd. (W.P.(C) 12122/2021) and Jeevantika Organic Farming LLP (W.P.(C) 12083/2025), the Court directed that 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, and shall be processed in accordance with law, subject to verification of land acquisition status by the competent authority; the petitioner's undertaking was accepted, is to be embedded in the Sale Deed to bind subsequent transferees, and registration is without prejudice to the pending consolidation proceedings and third-party rights.

¶1

$~90

¶2

IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 6458/2026, CM APPL. 31856/2026 JATIN GARG .....Petitioner Through: Mr. Anuroop P.S., Mr. Surinder Singh Rana and Mr. Aditya Sorout, Advocates.

¶4

versus

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THE GOVT OF NCT OF DELHI AND ANR .....Respondents Through: Mr. Lalltaksh Joshi and Ms. Mina Kumari, Advocates for GNCTD. Mr. Sanjay Kumar Pathak, SC for R-1 with Mr. Sunil Kumar Jha 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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% 12.05.2026

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The Petitioner is the beneficiary of a Release Deed dated 1^st December, 2025 executed in respect of land measuring 2 Bigha 14 Biswas out of Khasra No. 50//2 min (2-14), situated in the revenue estate of Village Kanjhawala, Delhi - 110081.

¶11

It is stated that Mr. Rakesh Jain, being the recorded co-owner in possession of the aforesaid land, executed the aforesaid Release Deed in favour of the Petitioner. The said document was presented before Respondent No. 2, i.e., Sub-Registrar-VI D (Kanjhawala), for registration on 1^st December, 2025 and a receipt/slip acknowledging presentation of the document was also issued on the same date.

¶12

According to the Petitioner, when he approached the office of Respondent No. 2 for collection of the registered document, he was informed that the registration process could not be completed unless a No

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This is a digitally signed order.

¶14

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 14/05/2026 at 12:36:56

¶15

Objection Certificate/Land Status Report [“ NOC/LSR ”] was obtained from the concerned authority on account of pendency of consolidation proceedings in Village Kanjhawala. Aggrieved thereby, the Petitioner has approached this Court.

¶16

Counsel for the Respondents submits that since the land in question falls in a village where consolidation proceedings are stated to be pending, registration of the subject document would require an NOC/LSR and verification from the competent authority.

¶17

Insofar as the insistence on an NOC/LSR founded on the pendency of 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 a sanction/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 was reiterated by this Court 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

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

¶20

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

¶21

This is a digitally signed order.

¶22

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 14/05/2026 at 12:36:56

¶23

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.

¶24

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.

¶26

(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.

¶27

(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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With the foregoing directions, the petition is disposed of, along with the pending application.

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SANJEEV NARULA, J

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MAY 12, 2026 nk

¶32

This is a digitally signed order.

¶33

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 14/05/2026 at 12:36:56

Jatin Garg v. the Govt of NCT of Delhi and Anr.

Case brief

What is this about?

What did the court decide?

Jatin Garg v. the Govt of NCT of Delhi and Anr.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Cases cited

Procedural history

Parties & counsel

Coram

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