Unregistered Lease Documents Inadmissible for Determining Property dispute: Supreme Court
In a significant judgment, the Supreme Court of India has held that unregistered lease documents cannot be considered admissible evidence for determining the purpose of a property lease. The decision, delivered by a bench comprising Hon’ble Justices Aniruddha Bose and Vikram Nath, underscores the importance of registration in property transactions.
The judgment emanated from a legal dispute in which the defendant sought to establish that a property lease was intended for manufacturing purposes. However, the lease agreement in question had not been registered, leading to a contentious legal issue.
The court, in its ruling, highlighted that an unregistered lease agreement could only be considered for collateral purposes, provided it was not the main point of contention in the legal dispute. The judgment relied on various precedents and legal provisions, emphasizing the role of registration in property leases.
Justice Aniruddha Bose, in the judgment, explained, “The expression ‘manufacturing purposes’ in Section 106 of the 1882 Act means purposes for making or fabricating articles or materials by physical labor, skill, or by mechanical power, vendible and useful as such.”
The decision reaffirms the principle that the burden of proving the purpose of a property lease, especially for manufacturing, rests with the party making the claim. The court stressed that in cases where the lease agreement itself was the primary point of dispute, its non-registration rendered it inadmissible as evidence.
The ruling is consistent with earlier judgments that have addressed the admissibility of unregistered lease agreements for specific purposes. It underscores the critical importance of registration in property transactions, providing legal clarity on the role of unregistered lease documents in establishing the purpose of property leases.
While this judgment clarifies the legal position regarding unregistered lease documents, it also serves as a reminder to parties involved in property transactions to ensure compliance with registration requirements to avoid potential legal challenges in the future.
Date of Decision: September 25th, 2023
M/S PAUL RUBBER INDUSTRIES PRIVATE LIMITED vs AMIT CHAND MITRA & ANR.
