Registrar Must Conduct a Summary Inquiry and Hear Parties Before Refusing Registration on a Temple’s Objection.

The petitioner claimed title to the property under a registered sale deed dated 14 February 1990.

When she presented a sale deed dated 9 July 2026 for registration in favour of Maheshkumar, the Sub Registrar issued a refusal check slip based on an objection by the Sankara Narayanan Temple.

The petitioner challenged that refusal and sought a direction to register the deed.

1. Whether the Sub Registrar could refuse registration on the Temple’s objection without following the procedure prescribed for objections by a religious institution.

2. Whether the refusal check slip should be quashed and the registration matter reconsidered after notice and a summary enquiry.

Under Section 22-A of the Registration Act, when a religious institution objects to registration, the registering authority must notify the parties to the deed and the objecting institution, conduct a summary enquiry, hear the parties, and pass an order either registering or refusing registration, having regard to the relevant facts.

This procedure was drawn from the Division Bench decision in Sudha Ravi Kumar v. The Special Commissioner and Commissioner, Hindu Religious and Charitable Endowments Department, (2017) 3 CTC 135.

The refusal was based on the Temple’s objection, bringing the matter within the procedure set out in Sudha Ravi Kumar.

The Court found that the Sub Registrar had to follow that procedure before reaching a final decision on registration.

It therefore set aside the refusal and remitted the matter for notice, a summary enquiry, an opportunity of hearing for both parties, and a fresh order in accordance with law.

It did not direct registration of the deed; the Sub Registrar was to decide the matter in accordance with law and the cited Division Bench guidelines.

The writ petition was disposed of without costs.