In MAHNOOR FATIMA IMRAN VERSUS M/S VISWESWARA INFRASTRUCTURE PVT. LTD (SUPREME COURT) 2025 INSC 646 the Supreme Court held that while registration of a document gives notice to the world that such a document has been executed is not to confer an unimpeachable validity on all such registered documents, an unregistered sale agreement does not confer valid title.
The Court explained Suraj Lamp & Industries Pvt. Ltd. v. State of Haryana (2012) 1 SCC 656 in the following words:
“Suraj Lamp & Industries Pvt. Ltd. v. State of Haryana cannot be understood to mean that title deeds; registered instruments of conveyance, are to be deemed valid unless set aside or declared void by a Civil Court of competent jurisdiction. There is no such dictum in the said decision wherein the Court was concerned with conveyances made on the strength of agreements of sale, General Power of Attorney and Wills. The issue addressed was avoidance of execution and registration of deed of conveyances as a mode of transfer of a free hold immovable property, especially in the teeth of Section 17 and Section 49 of the Registration Act. The tendency to adopt Power of Attorney sales along with execution of sale agreements and a bequeath by way of will, etc. instead of execution and registration of proper deeds of conveyance on receipt of full consideration was deprecated”