$~37 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010361092026 + W.P.(C) 11207/2026 SHRUTI DHAWAN .....Petitioner Through: Mr. Anand Yadav, Advocate. versus GOVT. OF NCT OF DELHI & ORS. .....Respondents Through: Ms. Harshita Nathrani, Advocate for Mr. Sameer Vashisht, SC (Civil), GNCTD. CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA O R D E R % 07.08.2026 1. The Petitioner states that a Sale Deed dated 10th March, 2026 was executed in her favour in respect of land measuring 2 Bighas 2 Biswas out of Plot No. 144/144 Min. East, measuring 0-13 Biswas, and Plot No. 144/145 measuring 1 Bigha 9 Biswas, situated in the Extended Lal Dora in the revenue estate of Village Kanjhawala, Delhi - 110081. It is stated that the said Sale Deed was presented for registration before the concerned Sub- Registrar soon thereafter. 2. The Petitioner submits that, despite presentation of the Sale Deed, the same has not been registered on account of the pendency of consolidation proceedings in Village Kanjhawala and the non-availability of an NOC/sanction from the competent authority. Aggrieved thereby, the Petitioner has approached this Court. 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 10/08/2026 at 12:30:44 3. Mr. Sameer Vashisht, Standing Counsel (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, 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. 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, particularly the stand taken by the Respondents, this Court is of the opinion that the present petition can be disposed of by issuing directions in similar terms. 7. Accordingly, it is directed as under: 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 10/08/2026 at 12:30:44 (i) The Petitioner shall file an undertaking by way of an affidavit 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 be filed within a period of two weeks from today. Upon filing of such an undertaking, the Petitioner shall remain bound thereby. (ii) Any breach of the aforesaid undertaking shall entail consequences in accordance with law. The said undertaking shall also form part of the Sale Deed, so as to put any subsequent transferee to notice of the subsisting undertaking. (iii) Subject to verification of the land acquisition status by the competent authority, and in line with the decisions in Okaya Infocom Pvt. Ltd. and Jeevantika Organic Farming LLP, it is directed that 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 the same 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 7, 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 10/08/2026 at 12:30:44