No, the judgment does not mean that rent (or mesne profits) cannot be assessed in the absence of a rental agreement or deed.

Key Reasons from the Judgment:

• Tenancy factum is independent of the deed's admissibility: The existence of a tenancy relationship was established through other evidence and admissions, even though the unregistered "Tenancy Agreement" (for 5 years) could not be used to prove its specific terms like duration or purpose. (!) (!) (!) (!) (!)
• Mesne profits decreed despite unregistered deed: The trial court granted the landlord's claim for recovery of possession as also decree for mesne profits, finding the tenant in default from October 2007. This was upheld by the High Court and Supreme Court, showing courts can assess/use/occupation compensation (mesne profits akin to rent) based on circumstances, default admissions, and record evidence (e.g., rent collection history until October 2007). (!) (!) (!)
• Post-expiry tenancy continues on statutory terms: After the initial period, tenancy held as month-to-month under Section 106 of the 1882 Act (non-manufacturing purpose), terminable by 15 days' notice. Rent/mesne profits liability persists as a holding over tenant, without needing the deed's terms. (!) (!) (!) (!)
• Unregistered deed limits only core terms: The deed is inadmissible for "any transaction affecting such property" (e.g., purpose/duration under Sections 105-107 TPA, Sections 17/49 Registration Act), but does not bar assessing fair rent/mesne profits from other facts like prior payments, enhancement demand (07.11.2007), and default. (!) (!) (!) (!) (!) (!) (!) (!)

Practical Implication:

Courts retain power to quantify mesne profits at market rates or prior paid amounts via evidence (e.g., witness statements, receipts), independent of an inadmissible deed. The suit succeeded precisely because rent liability was enforceable post-termination. (!) (!) (!)