Neha Dabas and Anr. Vs the Govt of NCT of Delhi and Anr.

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$~93

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 9244/2026, CM APPL. 43338/2026

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NEHA DABAS AND ANR .....Petitioners

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Through: Mr. Anuroop P.S. and Mr. S.S. Rana, Advocates.

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versus

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THE GOVT OF NCT OF DELHI AND ANR .....Respondents Through: Mr. Sanjay Kumar Pathak, SC with Mr. K.K. Kiran Pathak, Mr. Sunil Kumar Jha, Mr. Md. Sueb Akhtar and Mr. Kushagra Dixit, Advocates for R- 1.

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CORAM:

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HON'BLE MR. JUSTICE SANJEEV NARULA

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O R D E R

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% 13.07.2026

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The Petitioners state that a Sale Deed dated 25^th June, 2026 was executed in their favour in respect of Extended Lal Dora Plot bearing Khasra No. 143//909 (0-06), measuring 300 sq. yards, situated in the revenue estate of Village Kanjhawala, Delhi. It is stated that the said Sale Deed was presented for registration before Respondent No. 2/Sub-Registrar on 25^th June, 2026, and an acknowledgement receipt was issued on the same date. 2. 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 pendency of consolidation proceedings in Village Kanjhawala and the non-availability of an NOC/sanction from the competent authority. Aggrieved thereby, the Petitioners have approached

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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 15/07/2026 at 12:06:50

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this Court.

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Mr. Sanjay Kumar Pathak, SC 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. In view of the same, Mr. Pathak submits that, Respondent Nos. 1 and 2 are not insisting upon an NOC/sanction at this stage for registration of the aforesaid Gift 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 the stand taken on behalf of Respondents No. 1 and 2, this Court is of the opinion that the present petition can be disposed of by

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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 15/07/2026 at 12:06:50

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issuing directions in similar terms.

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Accordingly, it is directed as under:

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(i) The affidavits/undertakings already placed on record by the Petitioners are taken on record and accepted. The Petitioners 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. , Shailender Bansal and Jeevantika Organic Farming LLP , it is directed that registration of the sale deed dated 25^th June, 2026 shall not be refused solely on the ground of pendency of consolidation proceedings or nonavailability of any NOC/sanction in that regard, and the same 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 13, 2026 nk

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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 15/07/2026 at 12:06:50

Neha Dabas and Anr. v. the Govt of NCT of Delhi and Anr.

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Neha Dabas and Anr. v. the Govt of NCT of Delhi and Anr.

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