$~48 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 8650/2026 & CM APPL. 40543/2026 SUNITA & ANR. .....Petitioners Through: Mr. V.P Dabas, Mr. Raj Kumar Dabas, Advocates. versus G N C T OF DELHI & ORS. .....Respondents Through: Mr. Lalltaksh Joshi, Ms. Minu Kumari, Advocates for R-1 & 2. CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA O R D E R % 03.07.2026 1. Respondent No. 3 is the recorded owner of an Extended Lal Dora residential plot bearing No. 142/244 Min (1-16), situated in the revenue estate of Village Kanjhawala, Delhi. It is stated that Respondent No. 3 executed a Sale Deed dated 2nd June, 2023 in favour of Petitioner No. 1 in respect of 700 sq. yds. out of the aforesaid plot. It is further stated that Respondent No. 3 also executed a Special Power of Attorney for mutation in favour of Petitioner No. 2 and an Indemnity Bond in favour of Petitioner No. 1. The said documents were presented before Respondent No. 2 for registration on 2nd June, 2023. 2. The Petitioners submit that the Sale Deed, Special Power of Attorney for mutation and Indemnity Bond were presented before Respondent No. 2 on 2nd June, 2023 and were duly acknowledged vide Document Nos. 6726, 6729 and 6728, respectively. However, by a refusal order dated 5th June, 2023, Respondent No. 2 declined registration of the said documents on 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 06/07/2026 at 10:34:02 ground that the subject property is under consolidation proceedings and the requisite sanction/NOC had not been obtained. Aggrieved thereby, the Petitioners have approached this Court. 3. Mr. Lalltaksh Joshi, counsel for Respondents No. 1 & 2, 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, Mr. Joshi submits that, Respondents No. 1 and 2 are not insisting upon an NOC/sanction at this stage for registration of the aforesaid documents. 4. 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. 5. 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. 6. In view of the aforesaid legal position, and having regard to the facts of the present case, particularly in light of the stand taken by Respondents 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 06/07/2026 at 10:34:02 No. 1 and 2, this Court finds that the refusal order dated 5th June, 2023, founded on the pendency of consolidation proceedings and the insistence on a sanction/NOC cannot be sustained in law. The said refusal order is accordingly set aside, and the following directions are issued: (i) The affidavit/undertaking already placed on record by the Petitioners is taken on record and accepted. The Petitioners shall remain bound by the same. (ii) Any breach of the aforesaid undertaking shall entail consequences in accordance with law. The undertaking 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, SPA for mutation and Indemnity Bond 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. 7. With the foregoing directions, the petition, along with any pending application(s), stands disposed of. SANJEEV NARULA, J JULY 3, 2026/ab 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 06/07/2026 at 10:34:02