Shri Satpal Vs Govt of NCT of Delhi and Others

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$~97

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(C) 9933/2026 & CM APPL. 46205/2026 SHRI SATPAL .....Petitioner

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Through: Mr. Ashutosh Rana, Advocate.

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versus GOVT OF NCT OF DELHI AND OTHERS .....Respondents Through: Ms. Harshita Nathrani, Advocate for Mr. Sameer Vashisht, SC for GNCTD. Mr. Sanjay Kumar Pathak, Standing Counsel with Mr. Sunil Kumar Jha, Mr. M.S Akhtar, Advocates for LAC.

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CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA

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O R D E R % 22.07.2026

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The Petitioner states that one Mrs. Santosh executed a Sale Deed dated 25^th May, 2026, in favour of the Petitioner in respect of agricultural land ad-measuring 10 Biswa, out of Khasra No. 32/6 Min., situated in the revenue estate of Village Kanjhawala, Delhi–110081. It is stated that the said Sale Deed was presented for registration before Respondent No. 2 on the same date, and an acknowledgement receipt was issued.

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The Petitioner submits 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

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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 27/07/2026 at 15:32:09

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competent authority. Aggrieved thereby, the Petitioner has approached this Court.

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Mr. Sameer Vashisht, SC (GNCTD), appearing on behalf of Respondents, 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 thereof, Mr. Vashisht submits that the Respondents 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, particularly the stand taken by the Respondents, this Court is of

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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 27/07/2026 at 15:32:09

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the opinion that the present 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 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 May, 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 registration of the Sale Deed shall be without prejudice to the pending consolidation proceedings and 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 22, 2026/ab

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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 27/07/2026 at 15:32:09

Shri Satpal v. Govt of NCT of Delhi and Others

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Shri Satpal v. Govt of NCT of Delhi and Others

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