RCS must recommend regularization of flat allotments for verified members upon completion of procedural documentation and verification.

The Petitioners are residents of the Pink Cooperative Group Housing Society Ltd., which was registered in 1980 with 106 members

Though construction was completed in 1990 and possession handed over in 1991, the formal approval of allotment by the Registrar Cooperative Societies (RCS) remained pending for decades

In 2016, a Division Bench order in W.P.(C) 5649/2014 directed the RCS to regularize allotments for members who submitted necessary documentation

While 100 members were subsequently regularized, the three Petitioners—who had acquired flats from verified original members (Ms. Uma Bagga, Mr. Raj Pal Bhatia, and Ms. Barkha Arora)—remained un-regularized due to alleged non-submission of documents

The Petitioners sought regularization and the processing of their leasehold-to-freehold conversion applications

1. Whether the Petitioners are entitled to regularization of their flat allotments and recommendation for freehold conversion given that their predecessors-in-interest were verified members

2. Whether the RCS can withhold regularization for subsequent transferees when the original membership and physical occupancy have been established

The court primarily applied the procedural and regulatory framework of the Delhi Co-operative Societies Act, 1972 and the Delhi Co-operative Societies Rules regarding the verification and regularization of members in group housing societies

Statement on the doctrine derived from a case: It adhered to the precedent set by the Division Bench in the Society's earlier litigation (Pink Cooperative Group Housing Society Ltd. v. RCS), which established that upon verification of membership and submission of indemnity bonds and affidavits regarding property ownership, the RCS must recommend the names to the Delhi Development Authority (DDA) for title execution

The Court noted that the RCS had already verified a list of 105 members in 2016, which included the three original members from whom the Petitioners acquired their flats

Since neither the RCS nor the Society disputed the veracity of the Petitioners’ claims or their status as transferees, the delay was deemed purely procedural

The Court reasoned that since the predecessors' memberships were already on record, the subsequent transferees (the Petitioners) merely needed to complete documentation and clear outstanding dues to the Society

The Court exercised its writ jurisdiction to bypass the administrative deadlock between the Society and the RCS, setting a strict time-bound schedule for document verification and recommendation to the DDA

The Court held that the RCS must send the final recommendation for flat allotment and title execution to the DDA by May 31, 2026, and the DDA must complete the entire process by July 31, 2026

It ordered the Petitioners and Society officials to appear before the Assistant Registrar on April 27, 2026, for document verification; the Society was directed to issue No Objection Certificates (NOCs) upon clearance of dues