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Issues: Whether transactions styled as agreement to sell/general power of attorney/will transfers convey title or create any interest in immovable property.
Analysis: A sale of immovable property can be effected only by a registered instrument of conveyance. An agreement to sell does not by itself create any interest in or charge on the property, and the protection under section 53A is only a limited shield against the transferor. A power of attorney is merely an agency arrangement and does not transfer ownership. A will operates only upon death and is revocable during the lifetime of the testator; its registration does not convert it into a conveyance. Such composite arrangements may continue to operate as agreements to sell or support specific performance or possession-based defences within the statutory limits, but they are not substitutes for a duly stamped and registered sale deed.
Conclusion: Transactions of the nature of GPA sales or SA/GPA/WILL transfers do not convey title, do not amount to transfer, and are not a valid mode of transfer of immovable property; title passes only through a registered deed of conveyance.