Arbitration award directing future conveyance need not be compulsorily registered when it does not itself transfer immovable property rights.

An arbitration award is not compulsorily registrable when it does not itself create, declare, assign, limit or extinguish any present or future right, title or interest in immovable property, but only directs the execution of further documents that will effect the transfer. Such an award falls within the exception for instruments conferring a right to obtain another document, rather than the rule requiring registration of instruments that themselves operate on property rights. On that basis, the award remained admissible in evidence and was capable of being acted upon without compulsory registration.

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Issues: Whether an arbitration award directing parties to execute future documents for declaration and transfer of interests in immovable property required compulsory registration under the Registration Act, and whether it was therefore inadmissible in evidence and incapable of being made a rule of the court.

Analysis: The award did not itself purport to create, declare, assign, limit or extinguish any present or future right, title or interest in immovable property. It only directed the execution of further documents which, when executed, would effect such transfer or declaration. An award of this character falls within the exception for instruments that merely create a right to obtain another document, and not within the provision requiring compulsory registration of instruments that themselves create or extinguish rights in immovable property. The authorities relied upon by the Court supported this distinction between an award that itself effects a transfer and an award that merely contemplates a future conveyance.

Conclusion: The award did not require registration and was admissible in evidence.

Ratio Decidendi: An arbitration award is not compulsorily registrable where it does not itself create or extinguish rights in immovable property but merely confers a right to obtain a subsequent document that will do so.

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