Bijender Vs G N C T of Delhi & Ors.

The Petitioner states that Respondent No. 3 executed a Sale Deed dated 06^th May, 2026 in favour of the Petitioner in respect of his entire 1/3^rd share out of agricultural land bearing Khasra No. 86//19 (4-16), situated in the revenue estate of Village Ladpur, Delhi. It is stated that the said Sale Deed was presented for registration before the Sub-Registrar on 06^th May, 2026.

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The Petitioner submits that, despite presentation of the Sale Deed and issuance of an acknowledgement receipt dated 06^th May, 2026, the same has not been registered on account of the pendency of consolidation proceedings in Village Ladpur, and non-availability of a sanction/NOC from the competent authority. Aggrieved thereby, the Petitioner has approached this Court.

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Mr. Lalltaksh Joshi, counsel for Respondents No. 1 & 2, fairly submits that the issue raised in the present petition is covered by 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 03/07/2026 at 11:46:48

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decisions of this Court in Okaya Infocom Pvt. Ltd. & Anr. v. Govt. of NCT of Delhi & Anr.¹ and subsequent orders following the same. In view of the same, Mr. Joshi submits that, Respondents No. 1 & 2 are not insisting upon an NOC/sanction at this stage for registration of the aforesaid Sale Deed.

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Indeed, 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 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.

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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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For the foregoing reasons and having regard to the facts of the present case, and particularly in light of the stand taken by Respondents No. 1 & 2, 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

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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.

¶26

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 03/07/2026 at 11:46:48

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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. , Shailender Bansal 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/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, along with any pending application(s), stands disposed of.

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SANJEEV NARULA, J

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JULY 2, 2026 as

¶34

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 03/07/2026 at 11:46:48

Bijender v. G N C T of Delhi & Ors.

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Bijender v. G N C T of Delhi & Ors.

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