सूरज लैम्प एंड इंडस्ट्रीज बनाम हरियाणा राज्य
| Citation | (2012) 1 SCC 656 |
| Court | Supreme Court of India |
| Date | 11 October 2011 |
| Year | 2012 |
| Bench | R.V. Raveendran, A.K. Patnaik JJ. |
| Acts/Articles | Transfer of Property Act Section 54, Registration Act Sections 17 and 49, Indian Stamp Act |
| Category | Haryana-Specific, Property & Land Law |
Key Principle Established
Sale of immovable property through General Power of Attorney (GPA), Agreement to Sell, and Will is not a valid mode of transfer. Only a registered sale deed transfers title to immovable property.
The rampant practice of transferring immovable properties through General Power of Attorney (GPA), Agreement to Sell, and Will transactions — to avoid stamp duty and registration charges — was challenged before the Supreme Court.
The Supreme Court held that immovable property can only be legally transferred through a registered sale deed:
This Haryana-origin judgment is the most important decision on property transfer validity in recent times. It struck at the root of the widespread GPA-Sale practice prevalent across North India, especially Haryana, Delhi, and Punjab, and has fundamentally changed property transaction practices.
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Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.