Sunday, 24 July 2022

Whether a document can be registered after four month if it was presented within that time?

From the above, it is clear that no document other than a will shall  be accepted for registration unless presented to the Registering Authority within four months from the date of its execution. In the case on hand, it is obvious that the subject lease of agreement was executed on 20.11.2019 and appears to be presented before the Registering Authority and on acceptance and stated to have been orally given various dates to attend for registration drawn the Challan bearing No.5149659836504 on

12.03.2020, which is within the prescribed period of four months from the date of its execution and the actual date of four months would be completed on 20.03.2020. Though the statute makes it imperative to present an instrument for registration within four months from the date of its execution, no time is fixed within which a deed presented and accepted for registration must be registered; and, indeed, from the nature of the requirements of the Act, the period within which the registration must be completed could not have been fixed. Earlier, this

Court, in W.P. No.313 of 2020 on 01.10.2020, dealt with the similar

aspect and held at para 10 as under:

“….Since there is no period of limitation to register the

document, once it was presented before the authority

concerned within four (4) months after its execution and

when it was accepted for registration, registering the

document at a later stage i.e, on 31.08.2019 (after lapse of

22 years), cannot be faulted.” {Para 10}

 TELANGANA HIGH COURT

 WRIT PETITION No.15986 OF 2020

 Tata Consumer Products Limited and another Vs The State of Telangana

Coram: SRI JUSTICE N.V. SHRAVAN KUMAR

Dated 10.06.2022

Heard the learned counsel for the petitioners and the learned

Government Pleader for Revenue appearing for the respondents.

With their consent, this writ petition is disposed of at the threshold.

2. This writ petition has been filed questioning inaction of the

respondents No.3 and 4 in considering the representations dated

16.03.2020, 19.08.2020 and 08.09.2020, stated to have been made by

the petitioners, and seeking consequential direction to the

4th respondent to register the lease deed dated 20.11.2019 considering

the challan bearing No.5149659836504, dated 12.03.2020.

3. It is the case of the petitioners that they have entered into a lease

agreement dated 20.11.2019, pertaining to the subject property of the

writ petition, and the registration of the same was scheduled on

09.03.2020, but on the said day, the office of the Sub-Registrar,

4th respondent, was declared as a holiday. Subsequently, the date of

registration was rescheduled to on 16.03.2020 and the requisite stamp

duty of Rs.14,76,500/- was paid to the 4th respondent through bank

transfer on 12.03.2020.

4. While the things stood thus, as the 1st petitioner hails from

Bangalore, Karnataka State and due to the COVID-19 pandemic,

the State of Karnataka was placed under lockdown. Thus,

the presence of the 1st petitioner before the 4th respondent on 16.03.2020

has become impossible. Explaining the said reasons, the petitioners

stated to have made a representation on 16.03.2020 to the

4th respondent requesting to extend the validity of registering the lease

deed dated 20.11.2019. In view of the fact that the entire country was

placed under lockdown from 22.03.2020 onwards, the petitioners could

not appear before the 4th respondent for registration of the subject lease

agreement. It is also stated that subsequently the petitioners made

representations on 19.08.2020 and 08.09.2020 to the 3rd and 4th

respondents respectively with the similar aforesaid request.

5. Further, it is submitted that the petitioners were orally informed

that they can attend for registration of subject agreement on or before

20.09.2020, which was the date of expiry of the challan dated

12.03.2020 and as such, the date of registration was again rescheduled

between 11.09.2020 and 14.09.2020.

6. While so, the 1st respondent issued blanket G.O.Ms. No.102 dated

07.09.2020 with a direction to stop registration pertaining to immovable

properties across the State of Telangana with effect from 08.09.2020

until further orders.

7. Narrating the above circumstances, the learned counsel for the

petitioners submits that registration of subject agreement can be

extended as per the saving clause under Section 23 of the Registration

Act, 1908 (For short “the Act”) with the order of this Court. In view of the

above provision, he requested that the petitioners may be accommodated

in such peculiar circumstances for registering their subject lease deed by

extending the validity of registration period and challan dated

12.03.2020. Further, by placing a copy of the order dated 10.01.2022

passed in Miscellaneous Application No.2 of 2022 in Miscellaneous

Application No.665 of 2021 in Suo Motu Writ Petition (C) No.3 of 2020 by

the Hon’ble Apex Court, he contended that the period from 15.03.2020

till 28.02.2022 stand excluded for the purposes of limitation and

therefore, the same may be made applicable to the petitioners’ case also.

8. On the other hand, the learned Assistant Government Pleader for

Revenue submits that the official respondents will follow the procedure

contemplated under Section 71 of the Act, duly taking into consideration

the Section 23 of the Act.

9. For better appreciation of the case, Section 23 of the Act is

extracted hereunder:

“Time for presenting documents:- Subject to the

provisions contained in sections 24, 25 and 26, no

document other than a will shall be accepted for

registration unless presented for that purpose to the

proper officer within four months from the date of its

execution:

Provided that a copy of a decree or order may be

presented within four months from the date on which the

decree or order was made, or, where it is appealable,

within four months from the day on which it comes final.”

10. From the above, it is clear that no document other than a will shall

be accepted for registration unless presented to the Registering Authority

within four months from the date of its execution. In the case on hand,

it is obvious that the subject lease of agreement was executed on

20.11.2019 and appears to be presented before the Registering Authority

and on acceptance and stated to have been orally given various dates to

attend for registration drawn the Challan bearing No.5149659836504 on

12.03.2020, which is within the prescribed period of four months from

the date of its execution and the actual date of four months would be

completed on 20.03.2020. Though the statute makes it imperative to

present an instrument for registration within four months from the date

of its execution, no time is fixed within which a deed presented and

accepted for registration must be registered; and, indeed, from the

nature of the requirements of the Act, the period within which the

registration must be completed could not have been fixed. Earlier, this

Court, in W.P. No.313 of 2020 on 01.10.2020, dealt with the similar

aspect and held at para 10 as under:


“….Since there is no period of limitation to register the

document, once it was presented before the authority

concerned within four (4) months after its execution and

when it was accepted for registration, registering the

document at a later stage i.e, on 31.08.2019 (after lapse of

22 years), cannot be faulted.”

11. The Hon’ble Apex Court vide its order dated 10.01.2022 in

Miscellaneous Application No.2 of 2022 in Miscellaneous Application

No.665 of 2021 in Suo Motu Writ petition (C) No.3 of 2020 considering

the impact of the surge of the virus on public health and adversities

faced by the general public directed that the period from 15.03.2020 till

28.02.2022 shall stand excluded from the purposes of limitation as may

be prescribed under any general or special law in respect of all judicial or

quasi judicial proceedings.

12. In the present case, after perusing the record, admittedly the effect

of COVID-19 pandemic caused hardship to both the parties i.e.

petitioners and the respondents and that the petitioners made

representations from time to time and there is no negligence on the part

of the petitioners. Even as per the record, the Challan is paid on

12.03.2020 within the prescribed period of four months from the date of

execution of the subject lease deed dated 20.11.2019, which was

accepted by the Registering Authority and thereby the registration date

was initially scheduled on 09.03.2020 but due to declaration of holiday on the said day, thereafter the registration dates were rescheduled from

time to time. Since the Challan was paid and registration dates were

already scheduled from time to time no prejudice would be caused to the

respondents if the registration is carried out. In view of the same,

the petitioners’ case is found to be sustainable.

13. Having regard to the facts and circumstances of the case and the

submissions made by the learned counsel on either side and the

observations made in the order dated 01.10.2020 in W.P. No.313 of 2020

by this Court and the order dated 10.01.2022 passed by the Hon’ble

Apex Court in Miscellaneous Application No.2 of 2022 in Miscellaneous

Application No.665 of 2021 in Suo Motu Writ petition (C) No.3 of 2020,

into consideration, I deem it appropriate to dispose of the writ petition

with the following directions:

i) The respondents, particularly respondents No.3 and 4, before

whom the aforesaid representations stated to have been made,

are directed either to consider the representations dated 16.03.2020,

19.08.2020 and 08.09.2020 seeking extension of the validity of the

registration of the subject lease agreement dated 20.11.2019, coupled

with the provision of Sections 23 and 71 of the Act, and pass appropriate

orders, in accordance with law, within a period of four weeks, from the

date of receipt of a copy of this order, or

ii) To entertain the registration of subject lease deed dated 20.11.2019,

if it is otherwise in order, duly extending the validity of the registration of

subject lease deed and Challan bearing No.5149659836504, dated

12.03.2020.

iii) However, it will be open to the 4th respondent to refuse/receive the

document presented before him, if he has any other objection,

by duly assigning reasons in support of such decision and communicate

the said decision to the petitioners.

With the above directions, this writ petition is disposed of.

There shall be no order as to costs.

Consequently, miscellaneous applications, if any pending, shall

stand closed.

__________________________________

JUSTICE N.V.SHRAVAN KUMAR

Date: 10.06.2022


Print Page

No comments:

Post a Comment