Allowed

Jasjeet Singh v. the Govt of NCT of Delhi and Anr.

Delhi HC15 May 2026W.P.(C)/6721/2026

Case brief

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What is this about?

This order addresses a writ petition seeking registration of a sale deed for land in Kanjhawala, Delhi, stalled due to pending consolidation proceedings and lack of NOC/LSR. The High Court issued directions for registration subject to a petitioner's undertaking, relying on prior precedents.

What did the court decide?

The petitioner's undertaking is accepted, and the Sub-Registrar is directed to process the registration of the Sale Deed without refusing it solely on account of pending consolidation proceedings or n

Jasjeet Singh Vs the Govt of NCT of Delhi and Anr. — Property and Title | Delhi HC (2026)

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$~56

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 6721/2026, CM APPL. 33014/2026

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JASJEET SINGH .....Petitioner

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Through: Mr. S.S. Rana, Mr. Neeraj Rana, Mr. P.S. Anroop and Mr. Gopal Rana, Advocates.

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versus

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THE GOVT OF NCT OF DELHI AND ANR .....Respondents Through: Mr. Sanjay Kumar Pathak, SC with Mr. K.K. Kiran Pathak, Mr. Sunil Kumar Jha, Mr. Md. Sueb Akhtar and Mr. Kushagra Dixit, Advocates for R- 1. Ms. Harshita Nathrani, Advocate for Mr. Sameer Vashisht, SC for GNCTD.

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CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA

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O R D E R % 15.05.2026 1. The Petitioner is purchaser of 1/6^th share out of land measuring 17 Bigha 2 Biswas comprised in Khasra Nos. 99//7 South (4-6), 99//8 South (412), 99//13 North (4-6) and 99//14 North (3-18), situated in the revenue estate of Village Kanjhawala, Delhi.

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It is stated that the aforesaid share in the land was purchased by the Petitioner from the recorded co-owner, namely Ms. Amita Jhanji, for valid sale consideration, and a Sale Deed dated 21^st November, 2025 was duly executed in favour of the Petitioner.

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It is stated that the aforesaid Sale Deed was presented before

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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 20/05/2026 at 16:17:09

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Respondent No. 2, i.e., Sub-Registrar-VI D (Kanjhawala), for registration on 21^st November, 2025, and a receipt/slip acknowledging presentation of the document was also issued on the same date. However, Respondent No. 2 has not proceeded to register the document on account of non-availability of a No Objection Certificate/Land Status Report [“ NOC/LSR ”], purportedly owing to pendency of consolidation proceedings in Village Kanjhawala. Aggrieved thereby, the Petitioner has approached this Court.

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Counsel for the Respondents submits that since the land is under consolidation proceedings, any transfer would require NOC/LSR and verification from the competent authority. 5. 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 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 20/05/2026 at 16:17:09

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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.

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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 present 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 15, 2026/ nk

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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 20/05/2026 at 16:17:09

Jasjeet Singh v. the Govt of NCT of Delhi and Anr.

Case brief

What is this about?

What did the court decide?

Jasjeet Singh v. the Govt of NCT of Delhi and Anr.

Case brief

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