Karnataka High CourtProperty and Real Estate LawAdministrative and Public Law

Registration may be refused absent Phodi, Durasti, and an 11-E sketch identifying the land.

MR INESIO ALMEIDA COUNTINHO S/O JOSE PEDRO COUTINHOv.THE SUB REGISTRAR JOIDA

Registration may be refused absent Phodi, Durasti, and an 11-E sketch identifying the land.. MR INESIO ALMEIDA COUNTINHO S/O JOSE PEDRO COUTINHO vs THE SUB REGISTRAR JOIDA. Karnataka High Court. LawLens
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In brief

The question

1. Whether the petitioner could require the Sub-Registrar to register the sale deed without producing the required 11-E sketch and completing Phodi and Durasti.

The court held

The Court declined to issue the requested mandamus and disposed of the petition.

It also directed

It left the petitioner to secure implementation of the earlier order directing Phodi and Durasti and then seek registration in accordance with law.

01Facts

The petitioner claimed ownership of five properties in Survey No. 123 and sought to sell them. After an earlier writ petition, the High Court had directed the Revenue Authorities to conduct Phodi and Durasti of the entire survey number within six months; that direction had not been implemented.

¶ 2–8, 11–13

The petitioner later sought registration of a sale deed, but the Kaveri portal did not accept the documents and the Sub-Registrar declined physical registration. The petitioner asked the Court to direct registration without requiring an 11-E sketch, while the respondent maintained that the properties’ records were incomplete and that registration required proper property particulars.

¶ 2–8, 11–13

02Issues

i.1. Whether the petitioner could require the Sub-Registrar to register the sale deed without producing the required 11-E sketch and completing Phodi and Durasti.

¶ 5–9, 14–16

ii.2. Whether the Sub-Registrar could be faulted for declining registration where the required particulars identifying the properties had not been furnished.

¶ 13–16

03Law Applied

The Court applied the requirements of the Karnataka Land Revenue Act concerning Phodi and Durasti for proper identification and assessment of land, and treated production of an 11-E sketch as an essential document for registration of the landed properties in this case.

¶ 14–16

It found no provision of law had been shown that exempted the petitioner from producing the sketch. The Court cited no precedent.

¶ 14–16

04Reasoning

The five properties differed in measurement, nature and character, and the petitioner sought registration before the earlier direction for Phodi and Durasti had been implemented.

¶ 8–9, 14–16

The 11-E sketch produced by the petitioner related to Survey No. 15/1, not the properties in Survey No. 123 and its sub-numbers. In the absence of the required survey particulars and property identification, the Court held that the petitioner could not insist on registration or on physical acceptance of the deed; the Sub-Registrar could not be faulted for declining it.

¶ 8–9, 14–16

05Holding

The Court declined to issue the requested mandamus and disposed of the petition.

¶ 17–19

It left the petitioner to secure implementation of the earlier order directing Phodi and Durasti and then seek registration in accordance with law.

¶ 17–19
Karnataka High Court

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MR INESIO ALMEIDA COUNTINHO S/O JOSE PEDRO COUTINHOvsTHE SUB REGISTRAR JOIDA

Karnataka High Court · September 29, 2026

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