Smt. Naresh Kumari & Ors. Vs Govt. of NCT of Delhi & Ors.

The Petitioners state that Respondents Nos. 4 and 5 executed a Sale Deed dated 9^th April, 2021 in their favour in respect of land measuring 2 Bighas and 1 Biswa, bearing Khasra No. 142/241 (2-1), situated in the Extended Lal Dora Abadi of Village Kanjhawala, Delhi. It is stated that the said Sale Deed was presented for registration before Respondent No. 2/SubRegistrar on the same date, and an acknowledgement was also issued.

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The Petitioners submit that, despite presentation of the Sale Deed and issuance of the aforesaid acknowledgement receipt, the same has not been registered on account of the insistence on an NOC/sanction from the competent authority in view of the consolidation proceedings in Village Kanjhawala. Aggrieved thereby, the Petitioners have approached this Court. 3. Ms. Avni Singh, Panel Counsel (GNCTD), appearing on behalf of

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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 13/07/2026 at 16:15:55

¶16

Respondents No. 1 to 3, 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. In view of the same, Ms. Singh submits that, Respondents No. 1 to 3 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 on behalf of Respondents No. 1 to 3, 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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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.

¶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 13/07/2026 at 16:15:55

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(i) The Petitioners shall file an undertaking by way of an affidavit, stating that the factum of this order shall be disclosed in the event of any further transaction relating to the subject land, prior to the conclusion of the consolidation proceedings. Let the said undertaking bee filed within a period of two weeks from today. Upon filing of such an undertaking, the Petitioners shall remain bound thereby.

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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 7, 2026/ hc

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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 13/07/2026 at 16:15:55

Smt. Naresh Kumari & Ors. v. Govt. of NCT of Delhi & Ors.

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Smt. Naresh Kumari & Ors. v. Govt. of NCT of Delhi & Ors.

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