Monday, 20 January 2025

Supreme Court: Agreement For Sale Doesn't Transfer Title Or Create Interest In Property :

It is well settled that an agreement for sale in

respect of an immovable property does not transfer title in

favour of the purchaser under the agreement. In view of

Section 54 of the Transfer of Property Act, 1882, an

agreement for sale does not create any interest in the

property. The only mode by which an immovable property worth

more than Rs.100/- (Rupees one hundred) can be sold is by a

sale deed duly registered in accordance with the Indian

Registration Act, 1908. {Para 6}

 IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

 CIVIL APPEAL NOS. OF 2025

(Arising out of Diary No.38616 of 2018)

INDIAN OVERSEAS BANK  Vs.  M.A.S SUBRAMANIAN & ORS.

Dated: January 07, 2025.

O R D E R

Permission is granted to file civil appeals.

2. Delay condoned.

3. By consent of the parties, the appeals are taken up

for final hearing.

4. We have heard the learned senior counsel for the

appellant, the learned counsel appearing for respondent Nos.

5 to 9 and the learned counsel appearing for respondent

No.10.

5. The challenge in these appeals will have to be

confined to the findings recorded by the National Company

Law Appellate Tribunal, (for short, "the NCLAT") in

paragraph 16 of the impugned judgment which reads thus:

"16. We reject the averments made by the

Appellants that the land belonged to them. The

land was in possession of the Company under an

agreement which can be seen from the records that

against the transfer of shares the original owner

of the land had agreed to sell the land to the

Company. For long the land was in possession of

the Company and the Company was in possession by

way of part-performance of the contract and there

was nothing remaining to be done by the Company

except that late Shri M.A.Shanmugam had to

execute and register the sale deed which

unfortunately he could not do as he suddenly

passed away in a year of incorporation. The

Appellants cannot take advantage of the position

they hold as trustees to deprive the Company of

the possession of its land. The Appellants have

argued that the wives of original Petitioners 1

and 2 who were also near relatives of the

Appellants had litigated with them regarding the

partition of the properties left by late Shri

M.A.Shanmugam in which litigation the present

land was also included. The Appellants have

given details regarding those litigations and

their ending into compromise to argue that

original Petitioners had knowledge about the

disputes and thus they must be said to have come

without clean hands. We find that even if the

wives of the original Petitioners 1 and 2 had any

litigation with reference to the properties left

by Shri M.A.Shanmugam and their relationships

with the Appellants, those disputes cannot be

basis to say that the original Petitioners who

are shareholders in their own rights can be

debarred from making the claims they made in the

Company Petition. We have already discussed as

to how the sale deed dated 31.10.2011 was

executed which came to be entered into books of

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the District Registrar as Document No.1844/2013

and that the Company Petition filed on 25.10.2014

could not be said to be delayed. The argument of

the Appellants that the original Petitioners did

not disclose in the NCLT the lease deed,

settlement deed and litigations have no

substance. We hold that the petitioners could

maintain the petition in their individual rights

as share holders. We reject the arguments that

the original Petitioners brought the Company

Petition without having clean hands or that they

had suppressed material facts."

6. It is well settled that an agreement for sale in

respect of an immovable property does not transfer title in

favour of the purchaser under the agreement. In view of

Section 54 of the Transfer of Property Act, 1882, an

agreement for sale does not create any interest in the

property. The only mode by which an immovable property worth

more than Rs.100/- (Rupees one hundred) can be sold is by a

sale deed duly registered in accordance with the Indian

Registration Act, 1908.

7. In this case, the NCLAT has recorded a finding that

late Shri M.A.Shanmugam who was the owner of the property

subject matter of these appeals had agreed to sell the

property to the company against the transfer of shares of

the company in his favour. The NCLAT has recorded a finding

that the company was in possession by way of part

performance of the contract. Based on the said finding, the

sale deed dated 31st October, 2011 purportedly executed by the

legal representatives of late Shri M.A.Shanmugam has been

held as not binding on the company. So long as the original

owner had not sold the property by execution of a registered

sale deed, he continued to be the legal owner of the

property. Admittedly, he had not executed a sale deed in

favour of the company. Therefore, the NCLAT in its limited

jurisdiction could not have held that the sale deed dated

31st October, 2011 was not binding on the company as the

company was in possession by way of part performance of the

contract.

8. There is nothing placed on record to show that the

company filed a suit for specific performance for enforcing

the agreement made by late Shri M.A.Shanmugam. In the

circumstances, we set aside the declaration granted by the

NCLAT under the impugned judgment in the following terms:

"We declare that the sale deed dated 31.10.2011

executed by original Respondents 2 to 6 in favour

of original Respondent No.7 as not binding on the

Respondent No.1 Company."

9. While doing so, we make it clear that we have made no

adjudication on the ownership rights claimed by the

different parties pursuant to the sale deed dated

31st October, 2011 and the rights claimed by respondent No.10-

company as well as by the appellant. Their remedies to seek

declaration and/or to enforce their rights are kept open.

4

10. The appeals are accordingly partly allowed on the

above terms.

11. Needless to add that the remedies of the company are

also kept open.

..........................J.

 (ABHAY S.OKA)


 ..........................J.

 (UJJAL BHUYAN)

NEW DELHI;

January 07, 2025.


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