Unregistered sale agreements do not transfer valid title to immovable property under Section 54 of the Transfer of Property Act.

The plaintiffs (legal heirs of Keja Bai) filed a suit for declaration of ownership, permanent injunction, and possession of agricultural land in Village Semariya.

Keja Bai’s title originated from her father, Ramcharan.

Following revenue proceedings in 1998, the suit land was mutated in her name and partitioned from her relative, Dev Singh (Defendant No. 4).

Upon attempting to take possession, Keja Bai discovered that Defendants 1, 2, and 3 were in illegal occupation.

The defendants claimed title via unregistered purchase agreements executed by Dev Singh in 1997.

The Trial Court decreed the suit in favor of the plaintiffs regarding agricultural land but dismissed the claim for abadi land.

The First Appellate Court affirmed this judgment on 15.10.2015.

The defendants preferred this Second Appeal challenging the concurrent findings.

Whether the appellants acquired valid legal title to the suit property based on unregistered sale agreements/documents.

Whether the findings of the lower courts were perverse or involved a substantial question of law warranting interference under Section 100 of the CPC.

Whether the lower appellate court erred in rejecting an application for additional evidence under Order 41 Rule 27 of the CPC.

The court applied Section 54 of the Transfer of Property Act, 1882, and Section 17 of the Registration Act, 1908, which mandate that the transfer of immovable property valued above Rs. 100/- must be effected through a registered instrument.

Regarding procedural scope, the court relied on Section 100 of the Code of Civil Procedure (CPC), 1908, which limits Second Appeals to "substantial questions of law".

It further applied the principle from *State of Rajasthan v. Shiv Dayal* (2019) 8 SCC 637, holding that concurrent findings of fact cannot be disturbed unless they are perverse, based on no evidence, or contrary to the law.

The High Court observed that the revenue records (Kishtbandi Khatauni and loan passbook) consistently identified Keja Bai as the owner following a valid partition.

The court rejected the appellants' claim of ownership because their defense rested on unregistered agreements dated 28.10.1997 and 15.12.1997.

Under Section 54 of the Transfer of Property Act, such unregistered documents are legally incapable of transferring title.

Furthermore, the court found no procedural error in the First Appellate Court's rejection of the Order 41 Rule 27 application, noting that the documents were neither originals nor certified copies and no sufficient cause for their delay was provided.

The High Court concluded that the appellants were attempting to relitigate facts already determined by two lower courts without demonstrating any perversity or misapplication of law.

The court affirmed the concurrent findings of the Trial Court and the First Appellate Court.

The Second Appeal was dismissed, upholding the decree for restoration of possession of the agricultural land to the legal heirs of Keja Bai.