Supreme Court: Unregistered Lease Not Admissible As Evidence

The Supreme Court reaffirmed that an unregistered lease deed concerning immovable property is inadmissible as evidence in legal proceedings, in accordance with Section 17 of the Registration Act, 1908, and Section 49 thereof. The case involved a dispute where parties relied on an unregistered lease deed to establish tenancy rights, which was challenged for want of registration. The Court clarified that while oral agreements and unregistered documents may serve limited purposes such as proving collateral facts, they cannot be the basis for enforcing substantive rights in immovable property transactions. The bench underscored that mandatory registration ensures legal certainty, prevents fraud, and provides public notice of transactions affecting property rights. It further observed that permitting reliance on unregistered deeds would defeat the purpose of the statute and create uncertainty in property law. However, the Court also acknowledged that equitable considerations such as possession and part performance under Section 53A of the Transfer of Property Act may still provide limited protection in certain contexts, though not in the instant case. By rejecting the admissibility of the lease deed, the judgment reiterates the importance of compliance with statutory formalities in property transactions, ensuring predictability and safeguarding third-party interests. The decision has wide implications for property disputes, tenancy claims, and commercial leasing arrangements, reinforcing the criticality of registration in establishing legal validity of agreements.