Smt. Anupma Bansal v. Govt. Of NCT Of Delhi & ANR.

$~107 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 6650/2026 SMT. ANUPMA BANSAL .....Petitioner Through:

Ms. Bhawana, Advocate.

versus GOVT. OF NCT OF DELHI & ANR.

.....Respondents Through:

Ms. Avni Singh, Panel Counsel, GNCTD with Mr. Vaibhav Sharma, Advocate.

CORAM:

HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 14.05.2026 1.

Ms. Bhawana, counsel for the Petitioner, submits that the land in question falls in Village Singhola, Delhi, where consolidation proceedings are presently underway. In this regard, this Court notes that, by order dated 09th March, 2026 passed in CONT.CAS(C) 1725/2024 and connected matters, it was directed that any further transfer in respect of land forming part of consolidation proceedings in the aforesaid Village shall remain subject to further orders of this Court.

2.

This Court also notes that in W.P.(C) 5178/2026, vide order dated 20th April, 2026, it was clarified that the order dated 09th March, 2026 would not come in the way of registration of Sale Deeds already executed and presented for registration, albeit subject to the outcome of CONT.CAS(C) 1725/2024.

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

3.

In light of the foregoing, and having regard to the factual matrix of the present case, the relevant background and submissions, to the extent necessary for disposal of the present petition, are noted hereunder: 3.1.

The Petitioner is the purchaser of agricultural land measuring 1 Bigha and 19 Biswas out of Khasra Nos. 10//23 min (0-07) and 10//24 min (1-12), situated in the revenue estate of Village Singhola, Delhi - 110040. The Sale Deed in respect thereof was executed on 23rd October, 2024 for a valid sale consideration.

3.2.

It is stated that the aforesaid Sale Deed was duly presented before Respondent No.2 i.e., Sub-Registrar VI-E, Libaspur for registration on the very same day. However, the registration has not been completed on account of insistence upon a No Objection Certificate/Land Status Report ["NOC/LSR"] owing to pendency of consolidation proceedings in Village Singhola. Aggrieved thereby, the Petitioner has approached this Court. 4.

This Court has considered the aforenoted background and submissions. In view of the clarification issued by this Court in W.P.(C) 5178/2026, the pendency of proceedings in CONT.CAS(C) 1725/2024 would not, by itself, preclude registration of a Sale Deed already executed and presented for registration, subject however to further orders therein. 5.

Apart from the aforesaid, insofar as insistence on an NOC/LSR 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 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

proceed in accordance with law, without insisting upon any sanction, approval, or NOC linked exclusively to consolidation proceedings. 6.

The above legal position has also 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. 7.

In view of the aforesaid, the present petition is disposed of with the following directions:

(i) The Petitioner shall file an undertaking by way of an affidavit within a period of two weeks from today, stating that the registration of the Sale Deed shall remain subject to further orders passed in CONT.CAS(C) 1725/2024 and that the factum of the present order shall be disclosed in the event of any further transaction relating to the subject land, prior to the conclusion of the consolidation proceedings. Upon filing of such undertaking, the Petitioner shall remain bound thereby. (ii) Any breach of the aforesaid undertaking shall entail consequences in accordance with law. The undertaking shall also form part of the registered 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 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.

Sale Deed shall not be refused solely on the ground of pendency of consolidation proceedings or non-availability of any NOC/LSR 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.

The present petition is disposed of in the above terms. SANJEEV NARULA, J MAY 14, 2026/hc The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.