Rani @ Raniyamma Vs the Sub Registrar — Writ and Judicial Review | Madras HC (2026)

Rani @ Raniyamma Vs the Sub Registrar — Writ and Judicial Review | Madras HC (2026)

What the court decided

AI extract

Outcome

Writ petition disposed of on the above terms: impugned refusal check slip dated 30.12.2025 set aside; matter remanded to the registering officer; petitioners permitted to re-present the sale deed within two weeks; registering officer to issue notice to the agreement holders under Document No.8880 of 2024 and the petitioners and thereafter either register the sale deed or issue a speaking order of refusal within thirty days from the date of representation; no costs; connected W.M.P.No.2032 of 2026 ordered.

Issue for consideration

Whether the impugned refusal by the Sub Registrar, Shoolagiri, to register the petitioners' sale deed dated 18.12.2025 warrants reconsideration, given the subsisting agreement of sale (Document No.8880 of 2024) and the fact that the amendment introducing Section 34C in the Registration Act, 1908 (as applicable in Tamil Nadu) had not entered into force when the refusal check slip was issued on 30.12.2025.

Court's answer

When the impugned refusal check slip was issued on 30.12.2025, the amendment introducing Section 34C in the Registration Act, 1908, as applicable in Tamil Nadu, had not entered into force; in those circumstances the matter warranted re-consideration.

Ratio / Principle

The impugned refusal check slip is set aside and the matter is remanded to the registering officer.

Key takeaways

The petitioner is permitted to re-present the sale deed within two weeks from the date of receipt of a copy of the order.ratio¶¶28
Upon receipt of the re-presented sale deed, the registering officer shall, after issuing notice to the agreement holders under Document No.8880 of 2024 and to the petitioners, either register the sale deed or issue a speaking order of refusal.ratio¶¶28
Any refusal after such reconsideration must be by a speaking order issued within thirty days from the date of representation.

Detailed headnote1 paragraphs

Registration — Refusal check slip — Petitioners presented sale deed dated 18.12.2025 for registration before the Sub Registrar, Shoolagiri; registration declined citing a prior agreement of sale bearing Document No.8880 of 2024 — Held, when the refusal check slip was issued on 30.12.2025, the amendment introducing Section 34C in the Registration Act, 1908, as applicable in Tamil Nadu, had not entered into force; hence the matter warranted re-consideration — Impugned refusal check slip set aside and matter remanded to the registering officer — Petitioner permitted to re-present the sale deed within two weeks — On re-presentation, after notice to the agreement holders under Document No.8880 of 2024 and the petitioners, the registering officer to either register the sale deed or issue a speaking order of refusal within thirty days from the date of representation — Writ petition disposed of on the above terms, no costs; connected W.M.P. ordered.

WP No. 1934 of 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 03-02-2026

CORAM

THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY

WP No. 1934 of 2026 and W.M.P.No.2032 of 2026

RANI @ Raniyamma W/o.Rajendran, Residing at, No.4/219,Bajar Street, Shoolagiri village and Post, Shoolagiri Taluk, Krishnagiri District.

Thangarasu S/o.Rajendran, Residing at, No.4/219,Bajar Street, Shoolagiri village and Post, Shoolagiri Taluk, Krishnagiri District.

Sathya D/o.Rajendran, W/o.Manikandan, NO. 91/103A, Venkatesh Nagar, Hosur Town and Taluk, Krishnagiri District.

..Petitioner(s)

Vs

The Sub Registrar Office of The sub Registrar, Shoolagiri, Krishnagiri District.

..Respondent(s)

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WP No. 1934 of 2026

PRAYER : Writ petition is filed under Article 226 of the Constitution of India, pleased to issue a Writ of Certiorarified Mandamus, Calling for the records relating to the impugned proceeding vide RFL / Soolagiri/ 72/ 2025 dated 30.12.2025, on the file of the respondent herein, quash the same and consequently direct the respondent to register the sale deed dated 18.12.2025 presented by the petitioners for registration and release the document to the petitioners within a time period to be stipulated by this Hon’ble Court.

For Petitioner(s): Ms.U.Ramya

for Mr.R.Bharath Kumar

For Respondent(s): Mr.U.Baranidharan, Special Government Pleader **********

ORDER

The petitioners executed sale deed dated 18.12.2025 in favour of one Srinivasan and presented the same for registration. The request for registration was declined by citing agreement of sale bearing Document No.8880 of 2024.

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WP No. 1934 of 2026

Learned counsel for the petitioners submits that the agreement of sale stipulated that the balance sale consideration should be paid within three months. Since this stipulation was not complied with by the intending purchaser, she submits that lawyers’ notice dated 24.11.2025 was issued for cancellation of the agreement of sale.

Mr.U.Baranidharan, learned Special Government Pleader, accepts notice for the sole respondent. He submits that the matter may be remanded for reconsideration so as to enable notice to be issued to the intending purchasers under the agreement of sale before a fresh decision can be taken.

The impugned refusal check slip was issued on 30.12.2025. At that juncture, the amendment introducing Section 34C in the Registration Act, 1908, as applicable at Tamil Nadu, had not entered into force. In those circumstances, the matter warrants re-consideration. To facilitate the same, the impugned refusal check slip is set aside and the matter is remanded to the registering officer. The petitioner is permitted to re-present the sale deed within two weeks from the date of receipt of a copy of this order. Upon receipt thereof, after issuing notice to the agreement holders under Document No.8880 of 2024 and the petitioners herein, the registering officer shall either register the sale deed or

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WP No. 1934 of 2026

issue a speaking order of refusal within thirty days from the date of representation.

This writ petition is disposed of on the above terms. No costs. Consequently, the connected writ miscellaneous petition is ordered.

03-02-2026

Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To

The Sub Registrar Office of The sub Registrar, Shoolagiri, Krishnagiri District.

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WP No. 1934 of 2026

SENTHILKUMAR RAMAMOORTHY, J.

RNA

WP No. 1934 of 2026 and W.M.P.No.2032 of 2026

03-02-2026

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