Gourav Jain Vs G N C T of Delhi through Chief Secretary & Ors. — Delhi HC (2026) — LawSathi Research

Gourav Jain Vs G N C T of Delhi through Chief Secretary & Ors. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Petition disposed of with directions: Petitioner's undertaking accepted and made part of the Sale Deed; registration of the Sale Deed not to be refused solely for pendency of consolidation proceedings or non-availability of NOC/sanction, subject to verification of land acquisition status, without prejudice to consolidation proceedings and third-party rights.

Issue for consideration

Whether registration of the Petitioner's Sale Deed, presented before the Sub-Registrar on 18.06.2026, could be kept pending/refused on account of non-availability of an NOC/sanction linked to pending consolidation proceedings, and whether it should now be processed. +1 more

Court's answer

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, and shall be processed further in accordance with law, subject to verification of the land acquisition status by the competent authority.

Ratio / Principle

The Petitioner's affidavit/undertaking is taken on record and accepted; any breach shall entail consequences in accordance with law, and the undertaking shall form part of the Sale Deed so as to put any subsequent transferee to notice.

Key takeaways

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.ratio¶30
The underlying principle that registration cannot be stalled indefinitely on account of pending consolidation proceedings is equally applicable to the present case.ratio¶5

Detailed headnote1 paragraphs

High Court of Delhi (Sanjeev Narula, J.), W.P.(C) 8683/2026, order dated 03.07.2026: Writ petition disposed of directing that registration of the Petitioner's Sale Deed dated 18.06.2026 over agricultural land in Village Kanjhawala (purchased from Respondent No. 3), pending before Respondent No. 2, shall not be refused solely on the ground of pendency of consolidation proceedings or non-availability of any NOC/sanction, following Okaya Infocom Pvt. Ltd., Shailender Bansal and Jeevantika Organic Farming LLP. Registration is subject to verification of land acquisition status by the competent authority; the Petitioner's undertaking is accepted, forms part of the Sale Deed to bind subsequent transferees, and registration is without prejudice to consolidation proceedings and third-party rights.

$~56

IN THE HIGH COURT OF DELHI AT NEW DELHI

- W.P.(C) 8683/2026 & CM APPL. 40621/2026

GOURAV JAIN .....Petitioner

Through: Mr. V.P Dabas, Mr. Raj Kumar Dabas, Advocates.

versus

G N C T OF DELHI THROUGH CHIEF SECRETARY & ORS.

.....Respondents Through: Mr. Lalltaksh Joshi, Ms. Minu Kumari, Advocates for R-1 & 2.

CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 03.07.2026

Respondent No. 3 is the recorded owner of 1/6th share in agricultural land comprised in Khasra Nos. 10/9 (1-05), 11/1/2 (1-02), 12 (2-02), 19 (201), 46/10 (4-16), 47/5 (1-18) and 6 (4-05), and is also the recorded owner of agricultural land comprised in Khasra Nos. 65/15 (4-16) and 66/11 min (0-17), all situated in the revenue estate of Village Kanjhawala, Delhi. The Petitioner claims to have purchased the aforesaid land, admeasuring 8 Bighas 11.16 Biswas, from Respondent No. 3. It is stated that Respondent No. 3 executed a Sale Deed dated 18^th June, 2026 in favour of the Petitioner in respect thereof. The Sale Deed was presented for registration before the Sub-Registrar on the same date.

The Petitioner submits that, despite presentation of the Sale Deed and

This is a digitally signed order.

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 06/07/2026 at 10:33:57

issuance of an acknowledgement slip bearing Serial No. 2026/14/4086 dated 18^th June, 2026, the same has not been registered and continues to remain pending with Respondent No. 2. Aggrieved thereby, the Petitioner has approached this Court.

Mr. Lalltaksh Joshi, counsel for Respondents No. 1 & 2, fairly submit 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. 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.

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.

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.

For the foregoing reasons and having regard to the facts of the present

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

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

This is a digitally signed order.

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 06/07/2026 at 10:33:57

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.

Accordingly, it is directed as under:

(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.

(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.

(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.

(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.

With the foregoing directions, the petition, along with any pending application(s), stands disposed of.

SANJEEV NARULA, J

JULY 3, 2026/ab

This is a digitally signed order.

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 06/07/2026 at 10:33:57

This is a digitally signed order.

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 06/07/2026 at 10:33:57