$~62 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 2436/2026, CM APPL. 11862/2026 SMT. POONAM DEVI .....Petitioner Through: Mr. Ashutosh Rana, Advocate.

versus GOVT. OF NCT OF DELHI & ORS. .....Respondents Through: Mr. Sanjay Kumar Pathak, SC with Mr. K.K. Kiran Pathak, Mr. Sunil Kumar Jha and Mr. M. S. Akhtar, Advocates for R-3.

Mr. Lalltaksh Joshi and Ms. Minu Kumari, Advocates for R-1, 2.

CORAM:

HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 20.02.2026

1. The Petitioner is the purchaser of land ad-measuring 04 bigha and 12 biswa, comprised in Khasra No. 46//8 (West) (4-08) and 46//9 (East) (0-04), situated in the revenue estate of Village Khanjawala, Delhi – 110081, by virtue of a Sale Deed executed on 15^th May, 2025.

2. The said Sale Deed was duly presented for registration before Respondent No. 2, the concerned Sub-Registrar, on the date of its execution. It is stated that the seller, the purchaser and the witnesses were present, and the document was accepted for presentation, whereafter a registration receipt dated 15^th May, 2025, was issued.

3. Subsequently, vide a Refusal Order dated 17^th May, 2025, the Sub- Registrar declined to proceed with registration of the Sale Deed on the ground that consolidation proceedings are stated to be pending in Village Khanjawala. In view thereof, the Petitioner requires a No Objection Certificate from the competent revenue authority.

4. Counsel for the Respondents submits that in light of the pendency of consolidation proceedings, as noted by the Sub-Registrar, the document could not be registered without prior verification and permission from the competent authority.

5. The issue as to whether registration of a Sale Deed can be withheld solely on account of pendency of consolidation proceedings is no longer res integra. 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 an 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.

6. The aforesaid legal position has been reiterated in subsequent decisions, including 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.

7. 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 disposed of by issuing directions in similar terms.

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

8. Accordingly, it is directed as under:

(i) The Petitioner has already filed an undertaking by way of an affidavit, stating that the registration of the Sale Deed shall remain subject to the outcome of the consolidation proceedings and that the factum of this order shall be disclosed in the event of any subsequent transaction relating to the subject land prior to the conclusion of consolidation proceedings. The Petitioner shall remain bound by the said undertaking.

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

(iii) Subject to verification of the land acquisition status by the competent authority, and in line with the decisions of this Court referred to hereinabove, the registration of the Sale Deed presented by the