Disposed

Jitin Garg v. G.N.C.T of Delhi & Ors.

Delhi HC22 May 2026W.P.(C)/7303/2026

Case brief

AI extract

What is this about?

The Delhi High Court directed the Sub-Registrar to register a sale deed for agricultural land in Village Ladpur without insisting on a sanction from the consolidation authority. The Court relied on precedents to balance equities, requiring the petitioner to furnish an accepted undertaking regarding breaches while processing the deed subject to third-party rights.

What did the court decide?

Directions issued to the Sub-Registrar to register the Sale Deed without insisting on sanction under the consolidation proceedings, subject to an undertaking by the petitioner.

Jitin Garg Vs G.N.C.T of Delhi & Ors. — Land Acquisition | Delhi HC (2026)

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$~32

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 7303/2026 & CM APPL. 35693/2026 JITIN GARG .....Petitioner

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Through: Mr. Jai Nariyan, Mr. V.P Dabas, Advocates.

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versus

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G.N.C.T OF DELHI & ORS. .....Respondents Through: Ms. Harshita Nathrani, Advocate for Mr. Sameer Vashisht, Standing Counsel (Civil) for GNCTD.

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CORAM:

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HON'BLE MR. JUSTICE SANJEEV NARULA O R D E R

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% 22.05.2026

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The Petitioner is the purchaser of agricultural land being 18/1998^th share out of agricultural land admeasuring 99 Bighas 18 Biswas, comprised in Khasra Nos. 2//16 (4-09), 17 (4-14), 23 (4-16), 24 (4-16), 25 (4-16), 3//21 (6-07), 22/1 (0-14), 22/4 (2-11), 5//3 (4-16), 4 (4-16), 7 (4-16), 8 (4-16), 18//15/2 (4-12), 16/2 (4-12), 25/2 (4-07), 25/3 (0-05), 54//16 (4-16), 25 (016), 61//10 (4-16), 11 (4-16), 12 (4-03), 20 (3-01), 77//9/2 (0-11), 88//11 (416), 20 (4-16) and 21/1 (1-04), situated in the revenue estate of Village Ladpur, Delhi. It is stated that Respondent No. 4, namely Mr. Joginder Singh alias Jogender Singh, was the recorded co-owner/co-bhumidhar in respect of the aforesaid share in the said land.

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It is stated that the aforesaid share in the land was purchased by the Petitioner from Respondent No. 4 for valid sale consideration and a Sale Deed dated 20^th 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 the

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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 23/05/2026 at 12:40:55

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concerned Sub-Registrar on 21^st November, 2025 for registration and was duly acknowledged. 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.

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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 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 non-availability 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.

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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 consolidation proceedings, is equally applicable to the present case.

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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 23/05/2026 at 12:40:55

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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 sanction 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 22, 2026/ab

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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 23/05/2026 at 12:40:55

Jitin Garg v. G.N.C.T of Delhi & Ors.

Case brief

What is this about?

What did the court decide?

Jitin Garg v. G.N.C.T of Delhi & Ors.

Case brief

What is this about?

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