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Issues: Whether the certified copy of the company court order was presented for registration within the time permitted under the Registration Act so as to require acceptance by the registering authority.
Analysis: Section 23 of the Registration Act permits presentation of a copy of a decree or order within four months from the day on which the decree or order was made, or, where it is appealable, within four months from the day on which it becomes final. Section 25 permits acceptance of a document presented after the prescribed period, on payment of fine, where the delay does not exceed four months and the delay is due to urgent necessity or unavoidable accident. The dispute over implementation of the demerger scheme was finally settled only after dismissal of the connected appeal by the Division Bench, and the limitation was therefore held to run from the date on which that judgment became available to the petitioner. On that reckoning, the presentation was within time.
Conclusion: The certified copy of the order was held to be within the permissible time, and the registering authority was bound to accept it for registration, subject to compliance with other formalities.
Ratio Decidendi: For a copy of an appealable decree or order, limitation under Section 23 of the Registration Act runs from the date the order becomes final, and the registering authority cannot refuse registration when the document is presented within that period.