Dismissed

Smt. Jyoti Manoj Chilimbi v. State of Karnataka

Karnataka HC18 Mar 2026WP/33517/2025

Case brief

AI extract

What is this about?

This Single Judge Bench dismissed the writ petition filed to direct registration authorities to enquire into the alleged illegality of certain sale deeds. The Court held that registration authorities are functus officio once a document registered and lack jurisdiction to adjudicate disputed titles or fraud.

What did the court decide?

The writ petition invoking Article 226 is dismissed as it is not maintainable.

Smt. Jyoti Manoj Chilimbi Vs State of Karnataka — Property and Title | Karnataka HC (2026)

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NC: 2026:KHC:15904 WP No. 33517 of 2025

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HC-KAR

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18^TH DAY OF MARCH, 2026

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BEFORE

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THE HON'BLE MR. JUSTICE SACHIN SHANKAR MAGADUM WRIT PETITION NO. 33517 OF 2025 (GM-RES)

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BETWEEN:

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SMT. JYOTI MANOJ CHILIMBI W/O MANOJ CHILIMBI AGED ABOUT 62 YEARS RESIDING AT NO. 112/19, EMERALD ENCLAVE, ANGAHALLI, BEHIND INFOSYS, BELAGOLA POST, SRIRANGAPATNA TALUK, MANDYA DISTRICT - 571 606.

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…PETITIONER

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(BY SRI. KRISHNA MURTHY G, SR. COUNSEL FOR SRI. RUPESH KUMAR S, ADVOCATE)

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AND:

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Digitally signed by CHAITHRA A Location: HIGH COURT OF KARNATAKA

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STATE OF KARNATAKA REVENUE DEPARTMENT (STAMPS AND REGISTRATIONS), OFFICE AT M.S. BUILDILNG, AMBEDKAR VEEDHI, BENGALURU - 560 001, REP. BY UNDER SERETARY TO GOVERNMENT.

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THE DISTRICT REGISTRAR OKFFICE OF THE REGISTRAR MYSORE DISTRICT MYSORE - 570 001.

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NC: 2026:KHC:15904 WP No. 33517 of 2025

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HC-KAR

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THE SUB REGISTRAR

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OFFICE OF THE SUB REGISTRAR MIRLE VILLAGE, SALIGRAMA TALUK MYSORE DISTRICT - 571 603.

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MAHADEVA SHETTY S SON OF LATE SIDDASHETTY AGED MAJOR RESIDENT OF KAVERIPURA VILLAGE TALAKADU HOBLI, T. NARSIPURA TALUK MYSORE DISTRICT - 571 122.

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…RESPONDENTS

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(BY SMT. NAVYA SHEKHAR, AGA FOR R1 TO R3 AND R5)

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THIS WP IS FILED UNDER ARTICLE 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) ISSUE A WRIT OF CERTIORARI OR ANY OTHER WRIT OR DIRECTION THEREBY DIRECTING THE 2ND AND 3RD RESPONDENT AUTHORITIES TO CONDUCT AN ENQUIRY WITH RESPECT TO THE ILLEGAL REGISTRATION OF THE AGREEMENT TO SELL AND SALE DEEDS DATED 07.07.2025 PRODUCED AT ANNEXURES-A, B AND C AND ETC.,

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THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE SACHIN SHANKAR MAGADUM

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ORAL ORDER

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Heard the learned Senior Counsel appearing for the

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petitioner.

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NC: 2026:KHC:15904 WP No. 33517 of 2025

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HC-KAR

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The caption petition is filed seeking following

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reliefs:

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a) Issue a writ of certiorari or any other Writ or direction thereby directing the 2^nd and 3^rd respondent Authorities to conduct an enquiry with respect the illegal registration of the Agreement to Sell and Sale Deeds dated 07.07.2025 produced at Annexures-A. B and C.

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b) Issue a writ of certiorari or any other Wait or direction thereby quashing the Agreement to Sell dated 07.07.2025 registered on 10.07.2025 as document bearing No.MIR-1-01690-2025-26 stored in book-I registered before the 3^rd respondent authority in favour of 4^th respondent with respect to property bearing Sy No.118/03, measuring to an extent of 3 acres 18 guntas situated at Varuna Village, Varuna Hobli, Mysuru Taluk and District is herewith produced and marked as ANNEXURE-A.

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c) Issue a writ of certiorari or any other Writ or direction thereby and quashing the sale deed dated 07.07.2025 registered on 10.07.3035 as document bearing No.MIR-101693-2025-26 stored in book-I registered before the 3^rd respondent authority in favour of 4^th respondent with respect to property bearing Sy No.111/1, measuring to an extent of 2 acres 5 guntas situated at Varuna Village. Varuna Hobli, Mysuru Taluk and District is herewith produced and marked as ANNEXURE-B.

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d) Issue a writ of certiorari or any other Writ or direction thereby and quashing sale deed dated 07.07.2015 registered on 10.07.2025

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4 - NC: 2026:KHC:15904 WP No. 33517 of 2025

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HC-KAR

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as document bearing No.MIR-1-016912025-26 stored in book-1 registered before the 3^rd respondent authority in favour of 4^th respondent with respect to property bearing Sy No.118/2, measuring to an extent of 1 acres 07 guntas situated at Varuna Village, Varuna Hobli, Mysuru Taluk and District is herewith produced and marked as ANNEXURE-C.

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e) Pass such other direction/s, order/s as deemed fit to pass under the facts and circumstances of the case in the interest of justice and equity.

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4. This Court, on a careful and meaningful reading

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of the reliefs extracted supra, would find that the primary grievance of the petitioner is directed against the registration of the Agreement to Sell and the consequent Sale Deeds all dated 07.07.2025 and registered on 10.07.2025. The reliefs are couched in a manner seeking a writ in the nature of certiorari as well as a direction to respondent Nos.2 and 3 – the District Registrar and the Sub-Registrar to conduct an enquiry into the alleged illegality and thereafter to annul the said registered instruments. In this context, it requires to be noticed that the authorities under the Registration Act, 1908 (for short

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NC: 2026:KHC:15904 WP No. 33517 of 2025

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HC-KAR

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'the Act') exercise limited statutory functions, which are essentially administrative in nature, confined to registration of documents presented in accordance with the provisions of the Act. The scheme of the Act does not envisage adjudication by the registering authorities with regard to the validity, genuineness or enforceability of the underlying transaction embodied in a document. Once a document is admitted to registration in compliance with the statutory requirements, the Registering Authority becomes functus officio , save and except to the extent of powers expressly conferred under the Act. Therefore, the prayer seeking a direction to respondent Nos.2 and 3 to conduct an enquiry into the validity of the Agreement to Sell and the Sale Deeds and to set aside the same is wholly misconceived and dehors the statutory framework.

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Insofar as the reliance placed on the provisions

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akin to Sections 22-a, 22-b and 22-c of the Act is concerned, this Court has bestowed its anxious consideration to ascertain whether the case on hand would

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6 - NC: 2026:KHC:15904 WP No. 33517 of 2025

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HC-KAR

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fall within the limited ambit of enquiry contemplated under the said provisions. Sections 22-a to 22-c, as introduced

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by the State amendment, operate in a narrow field enabling the registering authority to refuse registration of documents which are statutorily prohibited, opposed to public policy, or relate to properties notified by the Government as non-transferable, including cases involving fraudulent or prohibited transactions as specified therein. The said provisions do not confer any adjudicatory jurisdiction upon the registering authority to embark upon a roving enquiry into disputed questions of title, alleged fraud between private parties, or the genuineness of contractual transactions. Such issues squarely fall within the domain of competent civil courts. In the present case, except making bald allegations regarding illegality in the execution and registration of the subject documents, the petitioner has failed to demonstrate that the transactions in question fall within any of the contingencies enumerated under Sections 22-a, 22-b or 22-c so as to attract refusal

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NC: 2026:KHC:15904 WP No. 33517 of 2025

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HC-KAR

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of registration or post-registration action by the registering authority. Consequently, this Court is of the considered opinion that no writ of mandamus can be issued directing respondent authorities to undertake an enquiry which is

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not contemplated under the statute. However, it is needless to observe that if the petitioner asserts any independent right, title or possessory interest over the subject property, it is always open to the petitioner to work out such remedies before the competent forum in accordance with law.

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Writ petition accordingly stands dismissed .

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SD/(SACHIN SHANKAR MAGADUM) JUDGE

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BVK

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List No.: 1 Sl No.: 4

Smt. Jyoti Manoj Chilimbi v. State of Karnataka

Case brief

What is this about?

What did the court decide?

Smt. Jyoti Manoj Chilimbi v. State of Karnataka

Case brief

What is this about?

What did the court decide?

What the court decided

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Issues for consideration

Statutes considered

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