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V.Sellaperumal, Vs The District Registrar — Writ and Judicial Review | Madras HC (2025)

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Madras HC
2025
V.Sellaperumal, Vs The District RegistrarV.Sellaperumal, v. The District Registrar

Allowed¶31

V.Sellaperumal, v. The District Registrar

Registration – Refusal under Section 22A, Registration Act, 1908

Madras HC8 Oct 2025WP(MD)/27804/2025

Case brief

AI extract

What is this about?

W.P(MD)No.27804 of 2025, Madurai Bench of Madras High Court, decided 08.10.2025 by G.R. Swaminathan, J. Sale deed registration refused by Sub Registrar, Manachanallur, Trichy citing Section 22A of the Registration Act, 1908; refusal check slip RFL/Manachanallur/202/2025 dated 30.08.2025 quashed after purchaser's undertaking affidavit to keep land agricultural; re-presentation permitted; registration directed subject to usual formalities; writ of certiorarified mandamus under Article 226 allowed; no costs; Temporary Document No. TP/231368344/2025.

What did the court decide?

Impugned refusal check slip (RFL/Manachanallur/202/2025 dated 30.08.2025) quashed; parties permitted to re-present the sale deed in Temporary Document No. TP/231368344/2025, which shall be registered and released subject to the other usual formalities; no costs.

Why is it important?

Recording the second petitioner's undertaking affidavit (to maintain the property as agricultural land and to convert it only with competent authority's permission), the Court quashed the impugned refusal check slip. ¶29

What the court decided

AI extract

Outcome

Impugned refusal check slip (RFL/Manachanallur/202/2025 dated 30.08.2025) quashed; parties permitted to re-present the sale deed in Temporary Document No. TP/231368344/2025, which shall be registered and released subject to the other usual formalities; no costs.

Issue for consideration

Whether the impugned refusal check slip refusing registration of the sale deed citing the Section 22A bar is illegal and liable to be quashed, and whether the second respondent should be directed to register the sale deed.

Ratio / Principle

Recording the second petitioner's undertaking affidavit (to maintain the property as agricultural land and to convert it only with competent authority's permission), the Court quashed the impugned refusal check slip.

Key takeaways

The parties were permitted to re-present the document; it shall be registered and released subject to fulfilment of the other usual formalities.ratio¶30
The Writ Petition was allowed accordingly, with no costs.ratio¶31

Detailed headnote1 paragraphs

Registration — Refusal under Section 22A, Registration Act, 1908 — Sale deed dated 30.08.2025 executed by first petitioner and others in favour of second petitioner refused registration by Sub Registrar, Manachanallur (refusal check slip RFL/Manachanallur/202/2025 dated 30.08.2025) citing Section 22A bar — At hearing, second petitioner/purchaser filed undertaking affidavit to maintain the property only as agricultural land and to convert it into house site or undertake housing development only after permission from the competent authority — Recording the undertaking, the Court quashed the refusal check slip and permitted the parties to re-present the document, to be registered and released subject to the other usual formalities — Writ Petition allowed, no costs.

A

W.P(MD)No.27804 of 2025

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

DATED : 08.10.2025

CORAM

THE HONOURABLE MR.JUSTICE G.R.SWAMINATHAN

W.P(MD)No.27804 of 2025

1.V.Sellaperumal

2.P.Rajeshwari

(P.2 is suo motu impleaded vide

order of this Court dated 08.10.2025)

... Petitioners

Vs.

1.The District Registrar, District Registrar's Office, Trichy.

2.The Sub Registrar, Sub Registrar Office, Manachanallur, Trichy District. ... Respondents

Prayer : Writ Petition filed under Article 226 of the Constitution of India, praying this Court to issue a Writ of Certiorarified Mandamus, to call for the records relating to the impugned refusal check slip issued by the second respondent in Refusal Number RFL/Manachanallur/202/2025 dated 30.08.2025 and quash the same as illegal and consequently direct the second respondent to register the sale deed executed by the petitioner

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W.P(MD)No.27804 of 2025

in Temporary Document No. TP/231368344/2025 within a stipulated time that may be fixed by this Court.

For Petitioners : Mr.J.Senthil Kumaraiah

For Respondents : Mr.D.Gandhiraj Special Government Pleader

ORDER

Heard both sides.

2.The first petitioner and others executed a sale deed dated 30.08.2025 in favour of the second petitioner. The document was presented for registration. Citing the bar under Section 22A of the Registration Act, 1908 registration was refused. Challenging the same, this writ petition has been filed.

3.When the matter was taken up for hearing, the second petitioner / purchaser filed an undertaking affidavit that the property purchased by her will be maintained only as an agricultural land. She further undertakes that she will convert the property as a house site or undertaking any housing development only after getting permission from the competent authority.

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W.P(MD)No.27804 of 2025

4.Recording the said undertaking, I quash the impugned refusal

check slip. The parties are permitted to re-present the document. It shall be registered and released subject to the fulfilment of the other usual formalities.

5.This Writ Petition is allowed accordingly. No costs.

08.10.2025

NCC : Yes / No Index : Yes / No Internet : Yes / No MGA

To

1.The District Registrar, District Registrar's Office, Trichy.

2.The Sub Registrar, Sub Registrar Office, Manachanallur, Trichy District.

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W.P(MD)No.27804 of 2025

G.R.SWAMINATHAN, J.

MGA

W.P(MD)No.27804 of 2025

08.10.2025

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Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the impugned refusal check slip refusing registration of the sale deed citing the Section 22A bar is illegal and liable to be quashed, and whether the second respondent should be directed to register the sale deed.¶15

Statutes considered

2 provisions across 2 enactments

AI extract

Constitution of IndiaArticle 226¶15
Registration Act, 1908Section 22A¶24

Procedural history

How this case reached the court

AI extract

Order under challenge
Refusal check slip issued by the second respondent refusing registration of the sale deed, Refusal Number RFL/Manachanallur/202/2025.¶15
Sub Registrar Office, Manachanallur, Trichy District (second respondent) · 30.08.2025
Prior proceeding
First petitioner and others executed a sale deed dated 30.08.2025 in favour of the second petitioner; the document was presented for registration and registration was refused citing the bar under Section 22A of the Registration Act, 1908, leading to this writ petition.¶24
Prior proceeding
At the hearing, the second petitioner/purchaser filed an undertaking affidavit that the property would be maintained only as agricultural land and converted to house site or housing development only with permission from the competent authority.¶25
Prior proceeding
The second petitioner (P.Rajeshwari) was suo motu impleaded by order of this Court dated 08.10.2025.¶9

Parties & counsel

AI extract

petitioner
V.Sellaperumal¶7
J.Senthil Kumaraiah
petitioner
P.Rajeshwari¶8
J.Senthil Kumaraiah
respondent
The District Registrar, District Registrar's Office, Trichy¶13
D.Gandhiraj
respondent
The Sub Registrar, Sub Registrar Office, Manachanallur, Trichy District¶14
D.Gandhiraj

Coram

AI extract

G.R.SWAMINATHANauthor¶5

Case details

As recorded by the court registry

Court: Madras HC
Decided on: 8 Oct 2025 · October
Registered: 6 Oct 2025
Case no.: WP(MD)/27804/2025
CNR: HCMD011393262025
Topic: Writ and Judicial Review
Bench: G.r.swaminathan
Disposal: ALLOWED
Case type: W.P(MD)

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Cite this judgement

V.Sellaperumal, v. The District Registrar, WP(MD)/27804/2025 (MAD), decided on 8 October 2025.

The Madras High Court publishes no neutral citation for this judgement — cite it by case number and date of decision.

Statutes2

Constitution of IndiaArticle 226
Registration Act, 1908Section 22A

View all statutes

Procedural history4

Refusal check slip issued by the second respondent refusing registration of the sale deed, Refusal Number RFL/Manachanallur/202/2025.Sub Registrar Office, Manachanallur, Trichy District (second respondent) · 30.08.2025
First petitioner and others executed a sale deed dated 30.08.2025 in favour of the second petitioner; the document was presented for registration and registration was refused citing the bar under Section 22A of the Registration Act, 1908, leading to this writ petition.
At the hearing, the second petitioner/purchaser filed an undertaking affidavit that the property would be maintained only as agricultural land and converted to house site or housing development only with permission from the competent authority.

View full history

Bench / Coram

G.R.SWAMINATHAN

Parties & counsel