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, Agreement to Sell, and Will (GPA-ATS-Will transactions) does not convey title. Only a registered sale deed transfers ownership.
The widespread practice in Haryana, Punjab, Delhi, and other northern States of transferring immovable property through General Power of Attorney (GPA), Agreement to Sell (ATS), and Will — to avoid stamp duty and registration charges — was challenged before the Supreme Court.
The Court declared unequivocally:
This Haryana-origin landmark effectively ended the rampant GPA sale practice in northern India. It has massive implications for real estate transactions in Haryana, where lakhs of properties were held through GPA sales. The judgment is cited in every property dispute involving informal transfers and is one of the most impactful property law decisions of the 21st century.
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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.