$~61 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 8010/2026 JEET SINGH .....Petitioner Through: Mr. Rajbir Singh Ruhil and Mr. Umesh Yadav, Advocates. versus ADDITIONAL DISTRICT MAGISTRATE (SOUTH WEST) AND OTHERS .....Respondents Through: Mr. Sanjay Kumar Pathak, SC with Mr. Sunil Kumar Jha, Mr. M.S. Akhtar, Ms. Joohu Kumari and Mr. Kushagra Dixit, Advocates for R-1. CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA O R D E R % 29.05.2026 1. The Petitioner claims to be a co-owner/co-sharer in possession of 1/20th share in Khata No. 106/99 comprising Khasra Nos. 1 etc./105 (5-09), 161 (0-09), 389 (19-03), 349 (4-15), 348 (7-14), 461 (0-14), 516 (3-14) and 634 (5-01), admeasuring in aggregate 46 Bighas 19 Biswas, situated in the revenue estate of Village Mundhela Khurd, Tehsil Najafgarh, New Delhi. 2. It is stated that, owing to his bona fide requirement, the Petitioner sold his aforesaid share for valid sale consideration and presented the Sale Deed dated 30th March, 2026 before Respondent No. 3, i.e., Sub-Registrar IX-A, Najafgarh, for registration. 3. It is stated that the aforesaid Sale Deed has not been registered and continues to remain pending on account of the pendency of consolidation proceedings in Village Mundhela Khurd and the insistence upon an NOC/sanction under Section 30 of the East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948. Aggrieved thereby, the This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/06/2026 at 12:31:07 Petitioner has approached this Court. 4. Counsel for the Respondents fairly submit that the issue raised in the present petition is covered by the decisions of this Court in Okaya Infocom Pvt. Ltd. & Anr. v. Govt. of NCT of Delhi & Anr.1 and subsequent orders following the same. In view of the same, it is submitted that, the Respondents are not insisting upon an NOC/sanction at this stage for registration of the aforesaid Sale Deed. 5. Indeed, in Okaya Infocom Pvt. Ltd., this Court 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/sanction. 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 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. For the foregoing reasons and having regard to the facts of the present case, and particularly in light of the stand taken by the Respondents, this Court is of the opinion that the writ petition can be disposed of by issuing directions in similar terms. 1 In W.P.(C) 12122/2021, decided on 10th November, 2023. 2 In W.P. (C) 12083/2025 & other connected matters decided on 12th August, 2025. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/06/2026 at 12:31:07 8. Accordingly, it is directed as under: (i) The Petitioner and the intending purchaser(s) shall file an undertaking(s) by way of an affidavit(s) 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(s) be filed within a period of two weeks from today. Upon filing of such undertaking(s), the Petitioner and the intending purchaser(s) shall remain bound thereby. (ii) Any breach of the aforesaid undertaking(s) shall entail consequences in accordance with law. The undertaking(s) shall also form part of the Sale Deed so as to put any subsequent transferee to notice. (iii) Subject to verification of the land acquisition status by the competent authority, and in line with the decisions in Okaya Infocom Pvt. Ltd., Shailender Bansal and Jeevantika Organic Farming LLP, it is directed that the registration of the Sale Deed shall not be refused solely on the ground of pendency of consolidation proceedings or non-availability of any NOC/sanction in that regard, and shall be processed further in accordance with law. (iv) It is clarified that the registration shall be without prejudice to the pending consolidation proceedings and shall remain subject to the rights, claims, and contentions of third parties, if any. 9. With the foregoing directions, the petition is disposed of. SANJEEV NARULA, J MAY 29, 2026/hc This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/06/2026 at 12:31:07