$~80 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010368492026 + W.P.(C) 11445/2026 & CM APPL. 53063/2026 ANJLI & ANR. .....Petitioners Through: Mr. V.P. Dabas, Advocate. versus G N C T OF DELHI THROUGH CHIEF SECRETARY & ORS. .....Respondents Through: Ms. Harshita Nathrani, Advocate for Mr. Sameer Vashisht, SC for GNCTD. CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA O R D E R % 11.08.2026 1. The Petitioners state that Respondent No. 3 executed a Sale Deed dated 08th September, 2025 in favour of Petitioner No. 1 in respect of his un- partitioned 31.33/476 share (31.33 Biswas) out of agricultural land measuring 23 Bighas 16 Biswas comprised in Khasra Nos. 17/5/1 (4-15), 19/12 (4-16), 24/1/1/2 (4-11), 10/3/2 (0-12), 12/3/1 (0-06), 2/2 (4-12) and 9/1/2 (4-04), situated in the revenue estate of Village Ladpur, Delhi. Respondent No. 3 also executed a Special Power of Attorney [“SPA”] dated 08th September, 2025 in favour of Petitioner No. 2 in respect thereof. It is stated that the said Sale Deed and SPA were presented for registration before the Sub-Registrar on the same date. 2. The Petitioners state that, despite presentation of the Sale Deed and SPA and issuance of acknowledgement receipts dated 08th September, 2025, the same have not been registered. A deficiency memo dated 16th September, 2025 was subsequently issued requiring an NOC/Land Status Report from the competent authority. The documents have consequently 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 17/08/2026 at 11:52:09 remained unregistered on account of the pendency of consolidation proceedings in Village Ladpur and non-availability of the requisite NOC/Land Status Report. Aggrieved thereby, the Petitioners have approached this Court. 3. Mr. Sameer Vashisht, SC (Civil), GNCTD, 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. Vashisht submits that, Respondents No. 1 & 2 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 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 17/08/2026 at 11:52:09 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. 7. Accordingly, it is directed as under: (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 and the SPA 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 AUGUST 11, 2026 nk 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 17/08/2026 at 11:52:09