Mamta Rani & Anr. Vs G N C T of Delhi through Chief Secretary & Ors.

The Petitioners are purchasers of agricultural land admeasuring 2 Bigha 8 Biswas out of the share of the vendor in land comprised in Khata No. 107/88, situated in the revenue estate of Village Ladpur, Delhi. It is stated that the vendor, i.e., Respondent No. 4, namely Ms. Suman, was recorded as Co-owner/Co-Bhumidhar in respect of the said land.

¶15

It is stated that the aforesaid land was purchased by Petitioner No. 1 from Respondent No. 4 for valid sale consideration and a Sale Deed dated 03^rd December, 2025 was duly executed in favour of Petitioner No. 1. It is further stated that a Special Power of Attorney [“ SPA ”] was also executed in favour of Petitioner No. 2 for the purposes of mutation.

¶16

It is stated that the aforesaid Sale Deed and Special Power of Attorney were presented before Respondent No. 3, i.e., the Sub-Registrar, VI-D,

¶17

W.P.(C) 6853/2026 Page 1 of 3

¶18

This is a digitally signed order.

¶19

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 17:06:08

¶20

Kanjhawala, on 03^rd December, 2025, after compliance with the requisite legal formalities. However, the documents have not been registered on account of pendency of consolidation proceedings in Village Ladpur and the requirement of sanction under Section 30 of the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948. Aggrieved thereby, the Petitioners have approached this Court.

¶21

Counsel for the Respondents submits that since the land is under consolidation proceedings, any transfer would require sanction and verification from the competent authority. 5. Insofar as insistence on a sanction 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/sanction. The Sub-Registrar was directed to proceed in accordance with law, without insisting upon any sanction, approval, or NOC linked exclusively to consolidation proceedings.

¶22

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 consolidation proceedings, is equally applicable to the present case.

¶23

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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W.P.(C) 6853/2026 Page 2 of 3

¶26

This is a digitally signed order.

¶27

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 17:06:08

¶28

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.

¶29

Accordingly, it is directed as under: (i) The affidavits/undertakings already placed on record by the Petitioners is taken on record and accepted. The Petitioners shall remain bound by the same.

¶30

(ii) Any breach of the aforesaid undertakings shall entail consequences in accordance with law. The undertakings shall also form part of the Sale Deed so as to put any subsequent transferee to notice.

¶31

(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 and the SPA shall not be refused solely on the ground of pendency of consolidation proceedings or non-availability of any sanction in that regard, and shall be processed further in accordance with law.

¶32

(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.

¶33

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

¶34

SANJEEV NARULA, J

¶35

MAY 18, 2026/ab

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W.P.(C) 6853/2026 Page 3 of 3

¶37

This is a digitally signed order.

¶38

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 17:06:08

Mamta Rani & Anr. v. G N C T of Delhi through Chief Secretary & Ors.

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Mamta Rani & Anr. v. G N C T of Delhi through Chief Secretary & Ors.

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