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2026 Supreme(Online)(Mad) 43825

IN THE HIGH COURT OF JUDICATURE AT MADRAS
D.Bharatha Chakravarthy, J
Anarkali – Appellant
Versus
Inspector General of Registration – Respondent
Writ Petition

Advocates:
For the Appellants/Petitioners: P.Edin Brough
For the Respondents: D.Gandhiraj

An interim injunction granted in a suit ceases to exist upon the withdrawal of the suit, and such an injunction cannot serve as a valid ground for refusing the registration of a sale deed.

Headnote:The petitioner challenged the refusal by the registration authority to register a sale deed, which was denied due to an existing interim injunction from a trial court. Upon verification, it was found that the underlying suit had been withdrawn, rendering the injunction ineffective. The Court determined that a withdrawn suit cannot justify the refusal of a document for registration. The principal issue was whether a registration authority can rely on an expired interim injunction from a withdrawn suit to refuse the registration of a deed. The Court reasoned that once a suit is withdrawn, the interim orders passed therein cease to exist, and therefore, they cannot serve as a legal impediment to property registration. The writ petition was allowed, the impugned refusal order was quashed, and the authority was directed to register the document upon presentation of the proof of withdrawal.

Table of Content
1. registration refusal due to pre-existing litigation and injunction. (Para 1 , 2 , 3)
2. injunctions from withdrawn suits cannot impede property registration. (Para 4 , 5)

ORDER

The present writ petition has been filed to quash the impugned refusal check slip dated 28.04.2026 and direct the 2^nd respondent to register the Sale Deed presented on 15.04.2026.

2. Heard Mr.P.Edin Brough, learned counsel for the petitioner and Mr.D.Ghandiraj, learned Special Government Pleader, who takes notice on behalf of the respondents 1 and 2.

3. Upon hearing the learned counsel appearing for the petitioner and perusing the material records of the case, it is the case of the petitioner that when she presented a sale deed for registration on 15.04.2026, the same was refused on the ground that an order of interim injunction had been granted by the learned District Munsif, Mudukulathur in O.S. No. 14 of 2018.

4. It is further the case of the petitioner that the suit in question has subsequently been withdrawn. Therefore, the existence of an interim injunction cannot be a valid ground for refusing registration after the suit has been withdrawn.

5. In view thereof the writ petition is allowed on the following terms:-

i. The impugned refusal check slip dated 28.04.2026 shall stand set aside.

ii. The petitioner is directed to present the Sale Deed along with a certified copy of the order of withdrawal of the suit in O.S. No. 14 of 2018. Thereupon, the Sale Deed shall be registered, if there is no other impediment. .

iii.No costs.

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2026 Supreme(Online)(Mad) 43825

IN THE HIGH COURT OF JUDICATURE AT MADRASD.Bharatha Chakravarthy, JAnarkali – AppellantVersusInspector General of Registration – RespondentWrit Petition

An interim injunction granted in a suit ceases to exist upon the withdrawal of the suit, and such an injunction cannot serve as a valid ground for refusing the registration of a sale deed.

IN THE HIGH COURT OF JUDICATURE AT MADRAS
D.Bharatha Chakravarthy, J
Anarkali – Appellant
Versus
Inspector General of Registration – Respondent
Writ Petition