$~101 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010420702026 + W.P.(C) 12982/2026 & CM APPL. 60312/2026 AJAY KUMAR .....Petitioner Through: Mr. Ashutosh Rana, Advocate. versus GNCTD & ORS. .....Respondents Through: Mr. Prateek Tanwar, SPC with Mr. Lovekesh Aggarwal, GP for UOI. Ms. Harshita Nathrani, Advocate for Mr. Sameer Vashisht, Standing Counsel (Civil) GNCTD. CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA O R D E R % 07.09.2026 1. The Petitioner states that the erstwhile owners executed a Sale Deed dated 22nd November, 2023 in his favour in respect of a residential plot admeasuring 275 sq. yds. out of Khasra No. 142/118, situated in the revenue estate of Village Kanjhawala, Delhi - 110081. The said Sale Deed was presented before the concerned Sub-Registrar/Respondent No. 2 on the same date, and an acknowledgement receipt was also issued. 2. The Petitioner states that, on 22nd November, 2023 itself, Respondent No. 2 refused to register the Sale Deed solely on the ground that consolidation proceedings in Village Kanjhawala were still pending and that issuance of the NOC from the Consolidation Officer had been stopped. Aggrieved thereby, the Petitioner preferred a statutory appeal under 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 14/09/2026 at 17:33:51 Registration Act, 1908 before Respondent No. 3, bearing Appeal No. 01/2024, which has remained pending till date. 3. The Petitioner has accordingly approached this Court seeking quashing of the aforesaid refusal order. The Petitioner has also sought, in the alternative, a direction to Respondent No. 3 to decide the statutory appeal preferred by him in a time-bound manner. 4. Counsel for the Respondents state that since the land is under consolidation proceedings, any transfer would require an NOC/sanction and verification from the competent authority. 5. Insofar as insistence on an NOC/sanction on account of pending consolidating proceedings is concerned, this Court, in Okaya Infocom Pvt. Ltd. & Anr. v. Govt. of NCT of Delhi & Anr.1, 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. 6. 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. 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 14/09/2026 at 17:33:51 7. In view of the aforesaid legal position, and having regard to the facts of the present case, this Court finds that the refusal order, being founded on the pendency of consolidation proceedings and the non-availability of an NOC, cannot be sustained in law. Accordingly, the refusal order dated 22nd November, 2023 is set aside, and the following directions are issued: (i) The affidavit/undertaking already placed on record by the Petitioner is taken on record and accepted. The Petitioner 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. and Jeevantika Organic Farming LLP, it is directed that the 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 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 SEPTEMBER 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 14/09/2026 at 17:33:51