Sunil Kumar Aggarwal v. G N C T of Delhi & Ors

O R D E R %

21.08.2026

¶1The Petitioner states that he is the purchaser of an undivided 1/6th share, admeasuring 3 Bighas 2 Biswas 10 Biswansis, out of agricultural land measuring 18 Bighas 15 Biswas, comprised in Khasra Nos. 9//10/2 (4-14), 14//12/1 (4-14), 13 (4-16) and 63//15 (4-11), situated in the revenue estate of Village Ladpur, Delhi – 110081. He purchased the aforesaid land by virtue of a Sale Deed dated 10th July, 2026 executed by Respondent No. 3 in his favour. He states that the said Sale Deed was presented for registration before the concerned Sub-Registrar on the same date and an acknowledgement receipt was also issued.

¶2The Petitioner states that, despite presentation of the Sale Deed and issuance of an acknowledgement receipt, the same has not been registered on account of the pendency of consolidation proceedings in the Village, and The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. non-availability of a sanction/NOC from the competent authority. Aggrieved thereby, the Petitioner has approached this Court.

¶3Mr. Sameer Vashisht, SC (Civil), GNCTD, submits that since the land is under consolidation proceedings, any transfer would require sanction and verification from the competent authority.

¶4Insofar as insistence on sanction/NOC on account of pending consolidation 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. The Sub-Registrar was directed to proceed in accordance with law, without insisting upon any sanction, approval, or NOC linked exclusively to consolidation proceedings.

¶5The 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.

¶6In view of the aforesaid legal position, and having regard to the facts of the present case, this Court is of the opinion that the present writ petition can be disposed of by issuing directions in similar terms.

¶7Accordingly, 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. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

(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., Shailender Bansal 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 sanction/NOC 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.

¶8With the foregoing directions, the petition, along with any pending application(s), stands disposed of.

SANJEEV NARULA, J AUGUST 21, 2026 as

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

* IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010388632026 + W.P.(C) 12073/2026 & CM APPL. 56014/2026 SUNIL KUMAR AGGARWAL .....Petitioner Through: Mr. V.P. Dabas, Advocate. versus G N C T OF DELHI & ORS. .....Respondents Through: Ms Harshita Nathrani, for Mr. Sameer Vashisht, SC (Civil) GNCTD. CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA