[Cites 2, Cited by 0]
Madras High Court
Satheesh Kumar vs The District Registrar on 19 February, 2026
Author: Krishnan Ramasamy
Bench: Krishnan Ramasamy
WP(MD). No.4634 of 2026
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
Date : 19/02/2026
CORAM
The Hon`ble Mr.Justice KRISHNAN RAMASAMY
WP(MD). No.4634 of 2026
Satheesh Kumar ... Petitioner
Vs
1. The District Registrar,
District Registrar Office,
Virudhunagar District..
2. The Sub Registrar,
Joint Ii Sub Registrar,
Virudhunagar,
Virudhunagar District.. ... Respondents
PRAYER :- Writ Petition filed under Article 226 of the Constitution of
India, praying this Court to issue a Writ of Certiorarified Mandamus,
directing the 2nd respondent to call for the records and to cancel the
impugned refusal check slip bearing refusal number RFL/JOINT II SUB
REGISTRAR VIRUDHUNAGAR/5/2026 dated 13.02.2026 issued by
the 2nd respondent and also direct to register the petitioners sale deed
presented on 13.02.2026.
For Petitioner : Mr.M.Viji
For Respondent : Mr.M.Lingadurai
Spl. Government Pleader
1/6
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WP(MD). No.4634 of 2026
ORDER
This writ petition has been filed challenging the refusal check slip
dated 13.02.2026 issued by the 2nd respondent and to direct the
respondent to register the sale deed dated 13.02.2026 presented by the
petitioner for registration.
2. Heard the learned counsel for the petitioner and the learned
Special Government Pleader for the official respondent. By consent of
both sides, the writ petition itself is taken up for final disposal at the
stage of admission itself.
3. When the petitioner presented the sale deed for registration, the
same was refused to be registered by the 2nd respondent on the ground
that the land in question to an extent of 37 cents is an unapproved
lay-out. It is his case that initially the petitioner's vendor, out of total 3
acres and 85 cents, sold 25.44 cents and now the petitioner purchased 37
cents. Since it is an agricultural land, challenging the said refusal, the
petitioner is before this Court.
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4. The learned counsel for the petitioner would submit that it is an
agricultural land and earlier the petitioner's vendor has not divided the
said land into lay-out or plots and now, the petitioner also intends to
purchase 37 cents of agricultural land without any subdivision and hence,
neither the question of approval nor bar under Section 22A would arise.
Hence, the learned counsel prays for interference.
5. Per contra, the learned Special Government Pleader would
submit that out of 3 acres 85 cents, the petitioner's vendor earlier sold
25.44 cents of land and in the remaining extent, he sold 37 cents of land
to the petitioner herein by way of the present sale deed. Therefore, it
came to light that the petitioner's vendor is selling the land by dividing it
as plots without there being any approval and in future also, they would
sell the land by dividing it as plots and hence, the authorities have rightly
rejected the document for registration.
6. I have considered the rival submissions and perused the
materials available on record.
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7. It appears that in the present case, the petitioner intends to
execute a sale deed for 37 cents of land. However, it is the stand of the
2nd respondent that the petitioner's vendor initially sold 25.44 cents of
land out of 3 acres and 85 cents and now the present sale deed is for 37
cents. If the respondent's contention is true, then they have to
substantiate whether any lay-out is formed as per the provision under
Section 22A of the Registration Act or the land has been divided into
plots. However, in the present case, the petitioner's vendor has not
divided the land into plots, ie., more than 8 plots as per Section 22A ie.,
as of now, the petitioner's vendor has sold only two portions of land, ie.,
25.44 cents and 37 cents respectively. G.O.No.78 dated 04.05.2017 says
that if it is more than eight plots, then it would be considered as lay-out.
The said G.O., also clarifies about lay-out. Lay-out means division of
land into plots exceeding eight in numbers in Chennai Metropolitan
planning area and division of land into plots by introducing a new road
or street in areas other than Metropolitan planning area. This Court is
inclined to apply the said G.O., to petitioner's case, since no other
definition is available for the word 'lay-out' etc. If such is the case, then,
in the present case, since the petitioner's vendor is selling only 37 cents
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of land without any sub division to the petitioner, as of now question of
forming lay-out or getting approval does not arise. For this reason, the
bar under Section 22A of the Registration Act also would not apply to the
present case. Without considering this aspect, the impugned order of
refusal is issued. Therefore, while setting aside the impugned order, the
petitioner is directed to represent the sale deed dated 13.02.2026 and
upon such representation, the 2nd respondent shall register the same
forthwith, if the same is otherwise in order.
8. The writ petition is disposed of with the above direction. No
costs.
19.02.2026
NCC : Yes/No
Index : Yes/No
RR
TO
1. The District Registrar,
District Registrar Office,
Virudhunagar District..
2. The Sub Registrar,
Joint II Sub Registrar,
Virudhunagar,
Virudhunagar District..
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KRISHNAN RAMASAMY, J
RR
ORDER
IN
Date : 19/02/2026
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