$~82 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 1884/2026 INDUPREET THUKRAL AND ORS. .....Petitioners Through: Mr. Anroop P.S., Mr. S.S. Rana, Mr.

Gopal Rana, Mr. Virender Kumar, Advocates.

versus GOVT OF NCT OF DELHI AND ANR .....Respondents Through: Ms. Avni Singh, Panel Counsel (Civil) with Mr. Vaibhav Sharma, Advocate for GNCTD.

CORAM:

HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 10.02.2026

1. The Petitioners are parties to a sale transaction in respect of land measuring 13 Bigha 10.33 Biswa (2.81 acres), comprised in Khasra Nos. 86/10 (1-02), 92/23 (0-02), 57/11 (3-18), 19/12 (1-05), 19/13 (0-11.33), 17 (1-04), 98/22 (1-14), 22/19 (0-16), 12 (1-02) and 98/10 (1-16), situated in the revenue estate of Village Kanjhawala, Delhi.

2. A sale deed dated 19^th November, 2025 has already been executed by Petitioner No. 3 in favour of Petitioners No. 1 and 2 and was presented for registration before Respondent No. 1/Sub-Registrar, Kanjhawala vide receipt/slip no. 2025/14/20792. However, the document has not been registered on account of insistence upon a sanction/NOC from the Consolidation Officer (Respondent No. 2). No formal order of refusal has been passed. The inaction has constrained the Petitioners to invoke the writ jurisdiction of this Court.

3. Counsel for the Respondents submits that the land in question is situated in a village where consolidation proceedings have been pending since long, and therefore sanction under Section 30 of the East Punjab Holdings (Consolidation and Fragmentation) Act, 1948 is required before registration of the sale deed.

4. Insofar as the insistence on a sanction/NOC founded on the pendency of consolidation proceedings is concerned, this Court in Okaya Infocom Pvt. Ltd. & Anr. v. Govt. of NCT of Delhi & Anr., In W.P.(C) 12122/2021, decided on 10th November, 2023., while dealing with the registration of sale deeds, held that having regard to the prolonged nature of consolidation proceedings, registration of such documents cannot be indefinitely withheld solely on the ground of non-availability of a sanction/NOC. The Sub-Registrar was directed to proceed in accordance with law, without insisting upon any sanction, approval, or NOC linked exclusively to consolidation proceedings.

5. The aforesaid legal position was reiterated by this Court 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.

6. In view of the aforesaid legal position, and having regard to the facts of the present case, this Court is of the opinion that the writ petition can be

2 In W.P. (C) 12083/2025 & other connected matters decided on 12th August, 2025.

disposed of by issuing directions in similar terms.

7. Accordingly, it is directed as under:

(i) The Petitioners No. 1 and 2 shall file an undertaking by way of an affidavit stating that the factum of this order shall be disclosed in the event of any further transaction relating to the subject land, prior to the conclusion of the consolidation proceedings. The undertaking already filed is taken on record and shall operate to the aforesaid effect. The Petitioners shall remain bound thereby.

(ii) Any breach of the aforesaid undertaking shall entail consequences in accordance with law. The said undertaking shall also form part of the proposed Sale Deed, so as to put any subsequent transferee to notice of the subsisting undertaking.

(iii) Subject to verification of the land acquisition status by the competent authority, and in line with the decisions in Okaya Infocom Pvt. Ltd. and Jeevantika Organic Farming LLP, it is directed that the registration of the proposed Sale Deed shall not be refused solely on the ground of pendency of consolidation