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M.Natrayan Vs The Sub Registrar Joint 2 — Writ and Judicial Review | Madras HC (2025)

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Madras HC
2025
M.Natrayan Vs The Sub Registrar Joint 2M.Natrayan v. The Sub Registrar Joint 2

Allowed¶35

M.Natrayan v. The Sub Registrar Joint 2

Registration – refusal check slip under Section 22-A of the Registration Act – sale of 11 cents in S.No.251/1B3, Sinthalagundu Village, Dindigul

Madras HC25 Feb 2025WP(MD)/4983/2025

Case brief

AI extract

What is this about?

W.P.(MD)No.4983 of 2025; Madurai Bench of Madras High Court; V. Lakshminarayanan J.; writ of certiorarified mandamus; Article 226; refusal check slip; Sub Registrar Joint 2 Dindigul; Section 22-A / Section 22A Registration Act; unapproved layout; Punja land; S.No.251/1B3 Sinthalagundu Village; 11 cents; vendor Veeraramu; D. Rajamanickam v. Sub Registrar Salem (West); W.P.No.426 of 2022; N. Sathish Kumar J.; Article 300-A; registration directed within two weeks; compliance 12.03.2025.

What did the court decide?

Impugned refusal check slip (RFL/Sub Registrar Joint 2 Dindigul/6/2025, dated 20.01.2025) set aside; respondent directed to register the petitioner's document within two (2) weeks from presentation; no costs; matter posted on 12.03.2025 for reporting compliance. ¶35

Why is it important?

On comparing the earlier sale deed with the present sale deed, the transfer is not of plots attracting Section 22A; the land held by Veeraramu as 'Punja land' is being alienated as 'Punja land' and, since the nature of the land is not being changed, Section 22A is not attracted. ¶32

What the court decided

AI extract

Outcome

Impugned refusal check slip (RFL/Sub Registrar Joint 2 Dindigul/6/2025, dated 20.01.2025) set aside; respondent directed to register the petitioner's document within two (2) weeks from presentation; no costs; matter posted on 12.03.2025 for reporting compliance.

Issue for consideration

Whether the Sub Registrar's refusal to register the petitioner's sale deed by reference to Section 22-A/22A of the Registration Act (bar relating to unapproved layouts/plots) is sustainable, when the land is being alienated as 'Punja land' without any change in its nature.

Court's answer

On comparing the earlier sale deed with the present sale deed, the transfer is not of plots attracting Section 22A; the land held by Veeraramu as 'Punja land' is being alienated as 'Punja land' and, since the nature of the land is not being changed, Section 22A is not attracted.

Ratio / Principle

In light of the above, the writ petition succeeds: the impugned refusal check slip dated 20.01.2025 is set aside, the respondent is directed to register the document within two weeks of its presentation by the petitioner, and no costs are awarded.

Detailed headnote1 paragraphs

Registration — refusal check slip under Section 22-A of the Registration Act — sale of 11 cents in S.No.251/1B3, Sinthalagundu Village, Dindigul — land alienated as 'Punja land' with no change in its nature, not a transfer of plots — Section 22A not attracted — Court follows D. Rajamanickam v. The Sub Registrar, Salem (West), W.P.No.426 of 2022 (N. Sathish Kumar J.) holding that the Section 22-A bar cannot be applied mechanically — impugned refusal check slip dated 20.01.2025 set aside; Sub Registrar Joint 2, Dindigul directed to register the document within two weeks of presentation; no costs; compliance reporting listed for 12.03.2025.

A

W.P.(MD)No.4983 of 2025

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

DATED: 25.02.2025

CORAM

THE HONOURABLE MR.JUSTICE V. LAKSHMINARAYANAN

W.P.(MD)No.4983 of 2025

M.Natrayan

... Petitioner

vs.

The Sub Registrar Joint 2, Office of Sub Registrar, Dindigul.

... Respondent

PRAYER: Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorarified Mandamus, to call for the records relating to the impugned refusal check slip passed by the respondent through proceedings in RFL/Sub Registrar Joint 2 Dindigul/6/2025 dated 20.01.2025 and to quash the same and further directing the respondent to register the sale deed of the petitioner.

For Petitioner : Mr.C.M.Mari Chellaiah Prabhu For Respondent : Mr.R.Suresh Kumar Additional Government Pleader

https://www.mhc.tn.gov.in/judis

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W.P.(MD)No.4983 of 2025

O R D E R

The petitioner seeks to quash the proceedings of the respondent in RFL/Sub Registrar Joint 2 Dindigul/6/2025, dated 20.01.2025.

The petitioner states that his vendor one Veeraramu was proposing to sell his property situated in S.No.251/1B3 of Sinthalagundu Village, Dindigul West Taluk, Dindigul District. On coming to know of this proposal, the petitioner approached the said Veeraramu and entered into negotiations with him. Pursuant to the negotiations, the petitioner also paid the entire sale consideration to his vendor and purchased the land to an extent of 11 cents in the aforesaid survey number. In this regard, when the petitioner presented the sale deed on 20.01.2025, the same came to be rejected by the impugned order. Hence, the writ petition.

The issue raised in the present writ petition is no longer res-

integra . It has been settled by the judgment of the Hon'ble Mr.Justice.N.Sathish Kumar in the case of D.Rajamanickam Vs., The

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W.P.(MD)No.4983 of 2025

Sub Registrar, Salem (West) in W.P.No.426 of 2022, dated 01.07.2024 . The learned Judge after referring several authorities and circulars had concluded as follows:

. “.......17. The clarification issued above would indicate that the bar contained under Section 22-A is only with regard to unapproved lay out which was formed without the permission for development from planning authority concerned and new roads or streets have been laid after the amendment and not in respect of the Unapproved Layout prior to the amendment came into being. Such view of the matter as the layout was formed in 2020 and several plots had already been sold, registration of settlement deed executed by the petitioner for the remaining extent of land retained and held by the petitioner in favour of his son cannot be refused. As already held such land can be used for any purposes other than housing development. Even any one of the adjacent land owners may wish to purchase such land for the purpose of using it as vacant land or for any other purpose other than housing development. Therefore, transfer of such land cannot be said to be totally prohibited, if transfer of such land is totally prohibited, it would certainly violate the constitutional right guaranteed under Article 300-A of the Constitution of India. The very object of introducing Section 22-A by way of Tamil Nadu Act is only to restrict conversion of agricultural land or any other land as unapproved house sites without the permission for development of such land from planning authority concerned. Therefore, bar contained under Section 22-A cannot be applied in

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W.P.(MD)No.4983 of 2025

a mechanical fashion and registration cannot be refused and restraining the owner of such land from using the land for any other purposes other than housing development.......”

Apart from this position, a comparison of the earlier sale deed

with the present sale deed shows that the transfer is not of plots to attract Section 22A of the Registration Act. It is only the land, that was under the custody of Mr.Veeraramu as 'Punja land', is being sold to the writ petitioner. It is being alienated as 'Punja land'. As the nature of land is not being changed, Section 22A is not attracted.

In the light of the above discussion, this Writ Petition succeeds

and the impugned refusal check slip passed by the respondent vide proceedings in RFL/Sub Registrar Joint 2 Dindigul/6/2025, dated 20.01.2025, is set aside.

In the result, this Writ Petition is allowed. The respondent shall register the document within two(2) weeks from the date of its presentation by the petitioner. No costs.

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W.P.(MD)No.4983 of 2025

Post on 12.03.2025 'for reporting compliance'.

Index :Yes / No Internet :Yes / No NCC :Yes / No Rmk

25.02.2025

To The Sub Registrar Joint 2, Office of Sub Registrar, Dindigul.

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W.P.(MD)No.4983 of 2025

V. LAKSHMINARAYANAN, J.

Rmk

W.P.(MD)No.4983 of 2025

25.02.2025

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https://www.mhc.tn.gov.in/judis

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the Sub Registrar's refusal to register the petitioner's sale deed by reference to Section 22-A/22A of the Registration Act (bar relating to unapproved layouts/plots) is sustainable, when the land is being alienated as 'Punja land' without any change in its nature.¶32
The court held
On comparing the earlier sale deed with the present sale deed, the transfer is not of plots attracting Section 22A; the land held by Veeraramu as 'Punja land' is being alienated as 'Punja land' and, since the nature of the land is not being changed, Section 22A is not attracted.ratio¶32

Cases cited

Colour shows how this judgement treated each authority

AI extract

D. Rajamanickam v. The Sub Registrar, Salem (West)Followed¶25
D.Rajamanickam Vs., The Sub Registrar, Salem (West) in W.P.No.426 of 2022, dated 01.07.2024

Statutes considered

4 provisions across 2 enactments

AI extract

Constitution of IndiaArticle 226¶12 Article 300-A¶26
Registration ActSection 22A¶32 Section 22-A¶26

Procedural history

How this case reached the court

AI extract

Order under challenge
Refusal check slip rejecting registration of the petitioner's sale deed, issued in proceedings RFL/Sub Registrar Joint 2 Dindigul/6/2025.¶12
Sub Registrar Joint 2, Office of Sub Registrar, Dindigul · 20.01.2025
Prior proceeding
Vendor Veeraramu proposed to sell land in S.No.251/1B3 of Sinthalagundu Village, Dindigul West Taluk; petitioner paid the entire sale consideration and purchased 11 cents in that survey number.¶19
Prior proceeding
Sale deed presented on 20.01.2025 was rejected by the impugned order, prompting the writ petition.¶19

Parties & counsel

AI extract

petitioner
M.Natrayan¶7
Mr.C.M.Mari Chellaiah Prabhu
respondent
The Sub Registrar Joint 2, Office of Sub Registrar, Dindigul¶10
Mr.R.Suresh Kumar

Coram

AI extract

V. Lakshminarayananauthor¶5

Case details

As recorded by the court registry

Court: Madras HC
Decided on: 25 Feb 2025 · February
Registered: 21 Feb 2025
Case no.: WP(MD)/4983/2025
CNR: HCMD010223152025
Topic: Writ and Judicial Review
Bench: V. Lakshminarayanan
Disposal: ALLOWED
Case type: W.P.(MD)

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Cite this judgement

M.Natrayan v. The Sub Registrar Joint 2, WP(MD)/4983/2025 (MAD), decided on 25 February 2025.

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

Cases cited1

D. Rajamanickam v. The Sub Registrar, Salem (West)Followed¶25

Open Authorities

Statutes4

Constitution of IndiaArticle 226 · Article 300-A
Registration ActSection 22A · Section 22-A

View all statutes

Procedural history3

Refusal check slip rejecting registration of the petitioner's sale deed, issued in proceedings RFL/Sub Registrar Joint 2 Dindigul/6/2025.Sub Registrar Joint 2, Office of Sub Registrar, Dindigul · 20.01.2025
Vendor Veeraramu proposed to sell land in S.No.251/1B3 of Sinthalagundu Village, Dindigul West Taluk; petitioner paid the entire sale consideration and purchased 11 cents in that survey number.
Sale deed presented on 20.01.2025 was rejected by the impugned order, prompting the writ petition.

View full history

Bench / Coram

V. Lakshminarayanan

Parties & counsel