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2026 Supreme(Online)(Tel) 14584

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
Pulla Karthik, J
Silpi Infra Private Limited – Appellant
Versus
State of Telangana – Respondent
Writ Petition Nos.33154, 34932, 34933, 35963, 35975, 35977, 36099, 36110 of 2025



Advocates:
For the Appellants/Petitioners: S. Sridhar
For the Respondents: Government Pleader for Stamps and Registration

The registration authorities lack the power to refuse the registration of documents based solely on administrative letters from District Collectors. Any prohibition of registration under Section 22-A(1)(e) of the Registration Act, 1908, must be supported by an official Gazette Notification as established by judicial precedent.

Headnote:(A) Registration Act, 1908 - Section 22-A - Prohibition of registration - Applicability of guidelines - The court held that inclusion of properties in a prohibitory list under Section 22-A(1)(e) requires a formal Gazette Notification by the State Government, and mere administrative letters from the District Collector are insufficient to restrict the registration of documents. (Paras 14, 15, 17, 20)

(B) Writ Jurisdiction - Disputed questions of fact - The court noted that determining the government's title over land, which involves historical record-keeping and competing claims, is a disputed question of fact that should ideally be adjudicated before a competent civil court rather than in a writ proceeding. (Para 13)

Facts of the case:
The petitioners sought the registration of sale deeds for flats constructed on land in Khanamet Village, which the respondents included in a prohibitory list as 'Laoni Patta (POT) - State Government' under Section 22-A of the Registration Act. The petitioners challenged the refusal orders, arguing that the land was private property and the authorities lacked the requisite notification to treat it as prohibited government land.

Findings of Court:
The court found that the refusal of registration based solely on administrative letters from the District Collector was contrary to law. As no official Gazette Notification had been issued as mandated by Section 22-A(2) and the binding guidelines in 'Vinjamuri Rajagopala Chary v. Principal Secretary', the Registering Authority erred in refusing to process the documents.

Issues: Whether the registering authority was justified in refusing registration based on administrative letters classifying the land as state-owned while lacking an official Gazette Notification under Section 22-A of the Registration Act, 1908.

Ratio Decidendi: Registration authorities cannot refuse to register documents based on unilateral letters or informal lists from district authorities that lack the statutory force of a published Gazette Notification required for properties under Section 22-A(1)(e) of the Registration Act, 1908.

Result: Petitions allowed; direction issued to register the documents subject to compliance with the Registration Act and Indian Stamp Act.

Table of Content
1. summary of facts leading to the refusal of property registration. (Para 1 , 2 , 3 , 4)
2. arguments presented by petitioners regarding legality of prohibition. (Para 5 , 6 , 7)
3. respondents' justification for including land in prohibitory list. (Para 8 , 9 , 10)
4. court discussions on the legal framework of section 22-a. (Para 11 , 12 , 13 , 14 , 15 , 16)
5. court's legal reasoning and final directive for registration allowance. (Para 17 , 18 , 19 , 20 , 21)

Since the lis in these writ petitions is one and the same, they are analogously heard together, and are taken up for disposal by way of this common order.

2. These Writ Petitions are filed seeking to declare and set aside the proceedings in Lr.No.E1/4483/2024 dated 15.03.2025 issued by respondent No.2, in including the lands in Sy.Nos.41/8 and 41/9 of Khanamet Village, Serilingampally Mandal, under GHMC, Ranga Reddy District (for brevity, ‘the subject land’), in the prohibitory list; and the refusal orders dated 29.10.2025 and 01.11.2025, respectively, passed by respondent No.4, as illegal, arbitrary, and contrary to the provisions of the Registration Act, 1908; and consequently, to direct respondent No.4 to register and release the sale deeds presented by the petitioners in respect of the Semi Furnished Flat Nos.201, 202, 301, 302, 401, 402, 501 and 502 respectively, in Block-C, Suryodaya Abode, in Plot Nos.21, 22 (part), 23, 24, 25, 26, 27 (Part), and 28, in Sy.Nos.41/8 and 41/9, situated at Khanamet Village, Serilingampally, Ranga Reddy District, (hereinafter referred to as, ‘the subject flats’).

3. The brief facts of the case are that petitioner No.2 herein is the absolute owner and possessor of the land admeasuring an extent of 2810 sq.yds., in H.No.2-42/46/D/21-24, on Plot Nos.21, 22, 23, 24, and H.No.2-42/46/D/25-28 on Plot Nos.25, 26, 27, 28, situated in Sy.Nos.41/8 and 41/9 of Khanamet Village, Serilingampally Mandal under GHMC Circle, Ranga Reddy District, having purchased the same under two registered sale deeds bearing Doc.Nos.10216 of 2006 dated 02.05.2006 and 10396 of 2006 dated 04.05.2006, from Mr. Syed Subjan Fareed Peer, rep. by his General Power of Attorney Mr. K. Lakshmaiah, and Mr. Syed Ashfaq Peer, respectively. Subsequently, GHMC had undertaken road widening works from Izzath Nagar to Ghousia Masjid Road (near Aurobindo), due to which, an extent of 224.54 sq.yds., on the eastern side of Plot Nos.25, 26, 27 and 28 was affected. Accordingly, the GHMC, vide letter dated 08.07.2020, requested petitioner No.2 herein to give consent for acquisition of the affected portion, subject to payment of compensation as per the prevailing R&B rates. As such, after acquisition of the said land, the total extent of petitioner’s land was reduced to 2585.45 sq.yds.

4. Later, petitioner No.2 divided the remaining land into three blocks, viz., Blocks-A, B and C, comprising of land admeasuring 902 sq.yds., 817.18 sq.yds., and 795.40 sq.yds, respectively, and entered into a development agreement with petitioner No.1-company. Accordingly, three development agreements were executed and registered between the petitioners bearing Doc.Nos.6289 of 2022, 6290 of 2022 and 6291 of 2022, all dated 22.02.2022. Thereafter, petitioner No.1, acting on behalf of petitioner No.2, had applied for building permission in Block-C, consisting of one stilt + five upper floors, and GHMC, having satisfied with the title and possession, granted building permit order No.1735/GHMC/SLP2/2023-BP dated 03.06.2023. Pursuant thereto, the residential building was constructed. Later, the petitioners executed a supplementary agreement vide registered Doc.No.14512 of 2024 dated 30.07.2024, for allocation of their respective flats, whereunder, the subject flats, i.e., Semi Furnished Flat Nos.201, 202, 301, 302, 401, 402, 501 and 502, of Block-C of Suryaodaya Abode, fell to the share of petitioner No.1. Petitioner No.2, along with petitioner No.1 herein, have executed sale deeds in favour of a t

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