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2026 Supreme(Online)(Mad) 44779

IN THE HIGH COURT OF JUDICATURE AT MADRAS
D. Bharatha Chakravarthy, J
A. Mani – Appellant
Versus
Sub-Registrar – Respondent
W.P(MD)No.11296 of 2026



Advocates:
For the Appellants/Petitioners: K. Prabhakar
For the Respondents: F. Deepak

The registration authority cannot refuse to register a document due to undervaluation; the mandatory procedure is to register the document and refer the issue of undervaluation to the appropriate authority under S.47-A of the Indian Stamp Act, 1899.

Headnote:The petitioner filed a writ petition challenging the respondent's refusal to register a sale deed, citing concerns over undervaluation. The court analyzed whether the respondent could withhold registration based on undervaluation concerns. The court addressed whether Guideline Value or undervaluation could be a valid ground for withholding the registration of a document. It held that the respondent cannot withhold registration based on valuation doubts; instead, the respondent must register the document and refer the matter to the appropriate authority under S.47-A of the Indian Stamp Act, 1899. The writ petition stands disposed of with a direction for the respondent to register the document and refer the valuation issue to the appropriate authority.

Table of Content
1. petitioner challenges the refusal to register a document due to undervaluation concerns. (Para 1 , 2 , 3)
2. registration of document is mandatory; valuation disputes must be referred under specific statutory provisions. (Para 4 , 5)

O R D E R

This writ petition is filed for a certiorarified mandamus calling for the records relating to the order dated 23.03.2026, thereby keeping the document as pending and consequently quash the same and direct the respondent to register and release the sale deed presented by the petitioner dated 23.03.2026.

2.The learned counsel for the petitioner would submit that without proper and sustainable reason, the document is kept as a pending document.

3.The learned Special Government Pleader took notice on behalf of the respondents, on written instructions, would submit that they have entertained some doubts about undervaluation, including wrongful fixation of guideline value and therefore, the document was kept pending. In any event, due orders will be passed.

4.I have considered the rival submissions made on either side and perused the material records of the case.

5.The fixation of guideline value etc cannot be the basis for withholding the document, if the respondent entertain a doubt with reference to the evaluation of the document, even then the respondents have to register the document at the same time refer the matter to the appropriate authority as per Section 47-A of the Act. Therefore, the respondent shall take a decision within a period of two weeks from the date of receipt of the web copy of the order and pass orders in the manner known to law. Even if the respondents are of the opinion that the document is undervalued and further duty has to be paid, the document has to be duly registered and the matter can be referred to the appropriate authority and it will be open for the petitioner to defend the said proceedings in the manner known to law. The aforesaid exercise shall be completed within a period of two weeks from the date of receipt of the web copy of the order.

6.With the above direction, this writ petition stands disposed of.

No costs.

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