$~67 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 2466/2026 JAGMOHAN AND ORS .....Petitioners Through: Mr. Rajbir Singh, Advocate.

versus A.D.M. (LA) (SOUTH - WEST) AND 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-1.

CORAM:

HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 20.02.2026

1. The Petitioners are co-owners / co-sharers in possession of 5/72th share, corresponding to 3 Bigha 6 Biswa and 6 Biswansi, out of agricultural land admeasuring 47 Bigha 15 Biswa, comprised in Khasra Nos. 1 etc.//281 (12-06), 372 (4-9), 385 (14-6), 507 min (1-10), 577 (6-17) and 27 (8-7), situated in the revenue estate of Village Mundhela Khurd, Tehsil Najafgarh, New Delhi.

2. The Petitioners, for their urgent bona fide needs, felt it necessary to sell their shareholding from the aforesaid agricultural land to a purchaser for certain sale consideration. Accordingly, a Sale Deed was entered into with the purchased and presented for registration before Respondent No. 3, the concerned Sub-Registrar. However, the said Sale Deed has not been processed further and continues to remain pending.

3. The reason cited for keeping the Sale Deed pending is the alleged requirement of a prior No Objection Certificate (“NOC”) / sanction from Respondents No. 1 and 2, on the ground that consolidation proceedings are stated to be pending in the village. Despite filing applications dated 25, In W.P.(C) 12122/2021, decided on 10th November, 2023. October, 2025 and 5^th January, 2026, with Respondents No. 2 and 1, respectively, neither has any sanction been granted nor has any formal order of refusal been communicated, constraining the Petitioners to invoke the writ jurisdiction of this Court.

4. Counsel for the Respondents submits that since the land is under consolidation proceedings, the Sub-Registrar could not proceed with registration without verification and permission from the competent authority.

5. Insofar as insistence on sanction/NOC on account of pending consolidation proceedings is concerned, this Court in Okaya Infocom Pvt. Ltd. & Anr. v. Govt. of NCT of Delhi & Anr.¹, 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

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

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.

8. Accordingly, it is directed as under:

(i) The Petitioners 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. Let the said undertaking be filed within a period of two weeks from today. Upon filing of such an undertaking, the Petitioners shall remain bound thereby.

(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 trans