Krishan Kumar Malik & Ors v. Govt. of NCT of Delhi and Ors

O R D E R %

25.08.2026

¶1The Petitioners state that Petitioner No. 1 is the intending purchaser of agricultural land bearing Khasra No. 1 etc./342, total admeasuring 10 Bigha 19 Biswa, situated in the revenue estate of Village Mundela Khurd, Tehsil Najafgarh, Delhi, while Petitioners No. 2 to 4 are the recorded co-owners/co-bhumidars thereof, represented through their common General Power of Attorney Holder, Ms. Indrawati @ Indu Malik. The Petitioners propose to execute and present for registration a Sale Deed in respect of the aforesaid land before the concerned Sub-Registrar.

¶2The Petitioners state that, upon enquiries with the Respondents, they The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. were orally informed that the proposed Sale Deed could not be registered without prior sanction/NOC from the competent authority, on account of the pending consolidation proceedings in Village Mundela Khurd. Aggrieved thereby, the Petitioners have approached this Court.

¶3Counsel for the Respondents 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, the Respondents submit that they are not insisting upon an NOC/sanction at this stage for registration of the proposed Sale Deed.

¶4Indeed, 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.

¶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.

¶6For 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. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. 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.

¶7Accordingly, it is directed as under:

(i) The affidavit(s)/undertaking(s) 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(s) shall entail consequences in accordance with law. The undertaking(s) shall also form part of the proposed 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 proposed 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.

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

SANJEEV NARULA, J AUGUST 25, 2026/nk 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. DLHC010402242026 + W.P.(C) 12449/2026 KRISHAN KUMAR MALIK & ORS. .....Petitioners Through: Mr. Viksit Singh, Mr. Deepanshu Malik and Ms. Garima Singh, Advocates. versus GOVT. OF NCT OF DELHI AND ORS. .....Respondents Through: Mr. Sanjay Kumar Pathak, SC with Mr. Sunil Kumar Jha, Mr. Md. Sueb Akhtar and Mr. Kushagre Dixit, Advocates for LAC. Mr. Lalltaksh Joshi and Ms. Minu Kumari, Advocates for R-4/GNCTD. CORAM: HON'BLE MR. JUSTICE SANJEEV NARULA