$~68 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 10220/2026 & CM APPL. 47366/2026 SUNIL KUMARI & ANR. .....Petitioners Through: Mr. Viksit Singh, Advocate. versus GOVT. OF NCT DELHI & ORS. .....Respondents Through: Ms. Harshita Nathrani, Advocate for Mr. Sameer Vashisht, SC (Civil), GNCTD. Mr. Sanjay Kumar Pathak, SC with Mr. Sunil Kumar Jha and Mr. M.S. Akhtar, Advocates for R-2. CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA O R D E R % 27.07.2026 1. The Petitioners state that Petitioner No. 2, Mrs. Sangeeta Jain, is the owner of agricultural land admeasuring 9 Bighas and 12 Biswas, comprised in Khasra No. 1 etc./253 Min. (9-12), situated in the revenue estate of Village Mundhela Khurd, Tehsil Najafgarh, New Delhi. It is stated that the Petitioners propose to execute a Sale Deed in respect of the aforesaid land, which is to be presented before the concerned authority for registration. 2. The Petitioners submit that, upon approaching the concerned Consolidation Officer (Respondent No. 3), prior to presenting the proposed Sale Deed for registration, they were orally informed that the same could not be registered on account of the pendency of consolidation proceedings in Village Mundhela Khurd and the non-availability of an NOC/sanction from 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 31/07/2026 at 14:04:04 the competent authority. Aggrieved thereby, the Petitioners have approached this Court. 3. 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 thereof, it is submitted that, the Respondents are not insisting upon an NOC/sanction at this stage for registration of the aforesaid Sale 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 case, and particularly in light of the stand taken on behalf of the Respondents, this Court is of the opinion that the writ petition can be 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 31/07/2026 at 14:04:04 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 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 proposed 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. 8. With the foregoing directions, the petition, along with any pending application(s), stands disposed of. SANJEEV NARULA, J JULY 27, 2026 as 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 31/07/2026 at 14:04:04