Smt. Shiksha Jain Vs Govt. of NCT of Delhi & Anr.

The Petitioner claims to be the purchaser of Industrial Property bearing No. 105, with roof rights upto sky, admeasuring 300 sq. yards out of Khasra No. 156/105 (0-06), situated in the Extended Lal Dora of Village Pooth Khurd, Tehsil Narela, Delhi - 110039. It is stated that the vendor, namely Mr. Achal Jain, was the owner of the said property.

¶13

It is stated that the aforesaid property was purchased by the Petitioner from Mr. Achal Jain for valid sale consideration and a Sale Deed dated 19^th May, 2026 was duly executed in favour of the Petitioner.

¶14

It is stated that the aforesaid Sale Deed was presented before Respondent No. 2, i.e., the Sub-Registrar, VI-B, Alipur, on 19th May, 2026 after compliance with the requisite legal formalities. The grievance of the Petitioner is that the document has not been registered and continues to remain pending on account of the pendency of consolidation proceedings in Village Pooth Khurd and the non-availability of a No Objection Certificate [“ NOC ”] from the Competent Authority. Aggrieved thereby, the Petitioner has approached this Court.

¶15

This is a digitally signed order.

¶16

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 29/05/2026 at 12:50:38

¶17

Mr. Abhinav Singh, Panel Counsel (Civil) for GNCTD, fairly submits that the issue raised in the present petition is covered by the decisions of this Court in Okaya Infocom Pvt. Ltd. & Anr. v. Govt. of NCT of Delhi & Anr.¹ and subsequent orders following the same. It is submitted that the Respondents have no objection if the present petition is disposed of in terms of the directions issued therein, subject to appropriate safeguards.

¶18

The aforesaid submission merits acceptance. In Okaya Infocom Pvt. Ltd. , this Court 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. The Sub-Registrar was directed to proceed in accordance with law, without insisting upon any sanction, approval, or NOC linked exclusively to consolidation proceedings.

¶19

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.

¶20

In view of the aforesaid legal position, having regard to the facts of the present case, and particularly in light of the stand taken by the Respondents, this Court is of the opinion that the writ petition can be disposed of by issuing directions in similar terms.

¶21

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

¶22

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

¶23

This is a digitally signed order.

¶24

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 29/05/2026 at 12:50:38

¶25

Accordingly, it is directed as under:

¶26

(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.

¶27

(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.

¶28

(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 in that regard, and shall be processed further in accordance with law.

¶29

(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.

¶30

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

¶31

MAY 25, 2026/ab

¶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 29/05/2026 at 12:50:38

Smt. Shiksha Jain v. Govt. of NCT of Delhi & Anr.

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Smt. Shiksha Jain v. Govt. of NCT of Delhi & Anr.

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