Smt. Anupma Bansal vs Govt. Of Nct Of Delhi & Anr.

$~21
* IN THE HIGH COURT OF DELHI AT NEW DELHI
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% Date of Decision: 01 July, 2026
+ W.P.(C) 5178/2026 & CM APPL. 39771/2026
SMT. ANUPMA BANSAL .....Petitioner
Through: Mr. V. P. Rana, Advocate
(M:9811165700)
versus

GOVT. OF NCT OF DELHI & ANR. .....Respondents
Through: Ms. Avni Singh, Panel Counsel for
GNCTD with Mr. Vaibhav Sharma,
Advocate
CORAM:
HON'BLE MS. JUSTICE MINI PUSHKARNA
MINI PUSHKARNA, J (ORAL):
CM APPL. 39771/2026
1. The present application has been filed on behalf of the petitioner
under Section 151 of the Code of Civil Procedure, 1908 (“CPC”) seeking
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direction to respondent no. 2 to register the sale deed dated 21 January,
2026, in accordance with the law laid down in W.P.(C) 12122/2021, titled as
Okaya Infocom Pvt. Ltd. & Anr. Versus Govt. of NCT of Delhi .
2. Learned counsel for the petitioner submits that in the judgment of
Okaya Infocom Pvt. Ltd. (Supra) , it had been directed that substantial
compliance of Section 30 of the East Punjab Holdings (Consolidation and
Prevention of Fragmentation) Act, 1948 (“EPH Act”) can be achieved by
directing that the intending purchaser of the said land will be bound by the
outcome of consolidation proceedings.
3. Thus, it is submitted that the purchaser can be bound by the outcome
Signature Not Verified
Digitally Signed
By:HARIOM SHARMA
Signing Date:02.07.2026
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W.P.(C) 5178/2026 Page 1 of 4

of the consolidation, and allottee can transfer the land by execution of the
sale deed.
4. It is therefore submitted that in this regard, directions may be issued
to the Sub-Registrar, Libaspur, Swarup Nagar, Delhi-110042 .
5. Issue notice. Notice is accepted by learned counsel for the
respondents.
6. Learned counsel for the respondents draws the attention of this Court
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to the Circular dated 14 August, 2025, issued by the Office of the
Divisional Commissioner, Government of NCT of Delhi (“GNCTD”),
wherein, it is stated that sanction under Section 30 of the EPH Act shall be
required only for the lands, situated in villages, where consolidation
proceedings are actively ongoing.
7. She further submits that as far as the Village Singhola is concerned,
the same shall be subject to the outcome of the contempt petition, i.e.,
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Cont.Cas(C) 1725/2024, in terms of the order dated 09 March, 2026,
passed therein.
8. Having heard learned counsels appearing for the parties, it is to be
noted that in the present case, sale of land has taken place in the revenue
estate of Village Singhola . However, the document pertaining to sale has not
been registered and has been kept pending on account of issues relating to
consolidation proceedings and non-availability of No Objection Certificate
(“NOC”)/Land Status Report (“LSR”) from the Consolidation Officer.
9. It is to be noted that consolidation proceedings are still pending in the
revenue estate of Village Singhola .
10. In the case of Smt. Payal Bansal Versus Govt. of NCT of Delhi &
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Anr., W.P.(C) 6422/2026, vide order dated 12 May, 2026, this Court, in
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By:HARIOM SHARMA
Signing Date:02.07.2026
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W.P.(C) 5178/2026 Page 2 of 4

view of the judgment passed in the case of Okaya Infocom Pvt. Ltd. (Supra) ,
has categorically held that registration of sale deeds cannot be indefinitely
withheld solely on the ground of non-availability of sanction/NOC. Such
directions were passed considering the fact of prolonged nature of
consolidation proceedings. Accordingly, the Court allowed the registration,
by requiring the intending purchaser to furnish an undertaking that they shall
be bound by the consolidation proceedings.
11. In view of the aforesaid legal position, the following directions are
issued:
i. Affidavit/undertaking by the petitioner as filed before the Sub
Registrar, Libaspur, Swarup Nagar, Delhi , 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.
iii. The undertaking shall form part of the sale deed, so as to put any
subsequent transferee to notice.
iv. Subject to verification of the land acquisition status filed by the
competent authority, and in line with the decision in Okaya Infocom Pvt.
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Ltd. (Supra) , it is directed that the registration of the sale deed dated 21
January, 2026 shall not be refused solely on the ground of pendency of the
consolidation proceedings or non-availability of NOC/LSR, in that regard.
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v. The request for registration of sale deed dated 21 January, 2026 shall
be processed in accordance with law. The sale deed shall be registered in a
time-bound manner.
12. It is clarified that the registration shall be without prejudice to the
pending consolidation proceedings, and shall remain subject to the rights,
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By:HARIOM SHARMA
Signing Date:02.07.2026
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W.P.(C) 5178/2026 Page 3 of 4

claims and contentions of the third parties.
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13. The registration of the sale deed dated 21 January, 2026 shall further
be subject to the orders passed in the pending contempt petition, i.e., Cont.
Cas(C) 1725/2024.
14. With the aforesaid directions, the present writ petition, along with
pending application, is disposed of.
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15. The next date of hearing, i.e., 06 August, 2026, stands cancelled.


MINI PUSHKARNA, J
JULY 1, 2026/au




Signature Not Verified
Digitally Signed
By:HARIOM SHARMA
Signing Date:02.07.2026
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W.P.(C) 5178/2026 Page 4 of 4