Prior agreement to sell creates no property interest, so an agreement-holder cannot block mutation or possession by a later registered transferee.

A prior agreement to sell does not by itself create any interest or charge in immovable property; it gives only a personal right to seek conveyance. Until specific performance is decreed and a sale deed is executed, the agreement-holder cannot claim title or restrain a subsequent transferee under a registered sale deed from taking possession, obtaining mutation, or enjoying the property through interim injunction. Broader disputes about the agreement's validity, arbitration clause, or competing rights were left for the substantive proceedings. The interim injunction was therefore not sustainable, and the revision was allowed in favour of the appellant.

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Issues: Whether a purchaser under an earlier agreement to sell, without a decree for specific performance, could restrain mutation and possession in favour of a subsequent purchaser by way of interim injunction.

Analysis: A contract for sale does not by itself create any interest in or charge on immovable property. It confers only a personal right to obtain a conveyance and does not amount to an estate in the property. Until a decree for specific performance is obtained and a sale deed is executed, the prior agreement-holder cannot claim title or interest in the property so as to prevent the transferee under a registered sale deed from enjoying the property, getting mutation effected, or taking possession. Any broader disputes about the validity of the agreement, arbitration clause, or competing rights were left to be decided in the substantive proceedings.

Conclusion: The interim injunction could not be sustained and the revision was allowed in favour of the appellant.

Ratio Decidendi: A prior agreement to sell does not create an interest in immovable property, and until specific performance is decreed and a conveyance executed, the agreement-holder cannot restrain a subsequent transferee under a registered sale deed from dealing with the property.

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