A subsequent purchaser cannot claim vehicle registration after the statutory registration period has expired.

The petitioner acquired two loaders from Pariyojna Nirman Private Limited under an agreement to sell dated 19 September 2019.

The vehicles had previously received temporary registration, which expired on 31 July 2017, but were never permanently registered.

The petitioner paid lifetime tax and charges for hypothecation endorsement and smart cards, yet the transport authorities did not issue permanent registration certificates.

The respondents stated that the previous owner had not completed the registration process under the former Vahan-2 system and that the Vahan-4 system would not permit the necessary backlog entry, including because of the vehicles’ emission classification and engine power.

After departmental efforts to resolve the issue did not result in registration, the petitioner sought a writ directing registration and permission to use the vehicles.

1. Whether the petitioner, as a subsequent purchaser who had paid tax and other charges, had an enforceable right to permanent registration of vehicles that had never been duly registered and whose temporary registration had expired.

2. Whether the Court could direct registration, or permit the vehicles to be plied, despite the applicable statutory restrictions and the expiry of the prescribed registration period.

The Court applied the Motor Vehicles Act, 1988 and the Central Motor Vehicles Rules, 1989, under which registration is a statutory requirement and payment of tax does not itself confer a right to registration or to use a vehicle on public roads.

It relied on Rule 115A(10), as amended by the Central Motor Vehicles (Twenty Sixth Amendment) Rules, 2021, notified through G.S.R. 800(E) dated 15 November 2021, which prescribed limited periods for registering vehicles manufactured before the applicability of the relevant CEV Stage-IV and Stage-V norms.

A writ court cannot compel a registering authority to act contrary to the governing statutory rules; administrative correspondence or technical efforts cannot create an entitlement inconsistent with those rules.

The Court also considered M.C. Mehta v. Union of India, (2021) 2 SCC 418, and Jashwant Singh v. State of Chhattisgarh & Ors., holding that they did not establish an unconditional right to registration independent of statutory requirements.

The vehicles had not obtained permanent registration before the temporary registration expired, and the former owner had failed to complete the required process under Vahan-2.

The petitioner’s later purchase and payment of tax and related charges could not cure that failure or create a vested right to registration.

Nor did the authorities’ efforts to resolve the Vahan-system problem establish an entitlement: those efforts could not override the statutory framework.

Because the prescribed registration period under the amended rules had elapsed, directing registration would have required the authorities to act contrary to the rules.

For the same reason, payment of tax or the earlier interim order could not justify continued use of the unregistered vehicles.

It dismissed the writ petition and vacated the interim order.

The dismissal did not preclude the petitioner from pursuing any remedy available in law against the previous owner; there was no order as to costs.