$~117 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 9644/2026 & CM APPL. 44966/2026 MANJEET KHARB & ORS. .....Petitioners Through: Mr. Viksit Singh, Mr. Deepanshu Malik, Advocates. versus GOVT. OF NCT DELHI & ORS. .....Respondents Through: Ms. Harshita Nathrani, Advocate for Mr. Sameer Vashisht, Standing Counsel (Civil) for GNCTD. Mr. Sanjay Kumar Pathak, SC with Mrs. K. Kaomudi Kiran Pathak, Mr. Sunil Kumar Jha, Mr. M.S Akhtar, Mr. Kushagra Dixit, Advocates for R2. CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA O R D E R % 21.07.2026 1. Petitioner No. 3 states that he is the recorded co-owner/co-bhumidhar of agricultural land situated in the revenue estate of Village Mundhela Khurd, Tehsil Najafgarh, New Delhi, the particulars whereof are set out in the petition. Petitioner No. 3, through his General Attorney, proposes to execute a Release Deed with consideration in favour of Petitioners No. 1 and 2, releasing his entire share in the subject land in equal shares. 2. It is stated that the proposed Release Deed could not be registered on account of the pendency of consolidation proceedings in Village Mundhela Khurd and the insistence upon a sanction/NOC from the competent 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 23/07/2026 at 12:12:48 authorities. Petitioner No. 3, through his General Attorney, submitted an application dated 25th June, 2026, seeking the requisite sanction/NOC, but no decision has been taken thereon. Aggrieved thereby, the Petitioners have approached this Court. 3. Mr. Sameer Vashisht, SC (Civil) for GNCTD, fairly submits 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. Vashisht submits that, Respondents No. 1 to 4 are not insisting upon an NOC/sanction at this stage for registration of the aforesaid Release Deed. 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. For the foregoing reasons and having regard to the facts of the present 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 23/07/2026 at 12:12:48 case, 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. 7. Accordingly, it is directed as under: (i) The affidavits/undertakings already placed on record by the Petitioners are taken on record and accepted. The Petitioners shall remain bound by the same. (ii) Any breach of the aforesaid undertakings shall entail consequences in accordance with law. The undertakings shall also form part of the proposed Release 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 proposed Release 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. 8. With the foregoing directions, the petition, along with any pending application(s), stands disposed of. SANJEEV NARULA, J JULY 21, 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 23/07/2026 at 12:12:48