Priority of competing registered sale deeds depends on party intention, consideration, delivery, and retrospective operation under registration law.

Where rival registered sale deeds compete, priority turns on the operative intention behind the conveyances, not registration alone. Section 50 of the Registration Act was held inapplicable because both instruments were registered; the real question was whether title was intended to pass on registration or only on payment of consideration and delivery of the deed. On the stated facts, unpaid consideration and the vendor's retention of the plaintiff's deed indicated that title was not meant to pass by registration alone. The defendant's deed, being supported by consideration, delivered, and executed earlier, was treated as operating from the date of execution under Section 47, so the plaintiff's deed did not prevail.

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Issues: Whether the plaintiff's registered sale deed prevailed over the defendant's registered sale deed, and whether title passed on registration notwithstanding non-payment of consideration and retention of the deed by the vendor.

Analysis: Section 50 of the Registration Act had no application because both instruments were registered. The decisive question was whether the parties intended title to pass upon registration alone or only on payment of consideration and delivery of the deed. As the consideration was found unpaid and the vendor retained the deed, the circumstances showed that title was not intended to pass merely by registration. By contrast, the defendant's deed was supported by consideration, was delivered, and was found to have been executed earlier, so Section 47 of the Registration Act operated in his favour from the date of execution.

Conclusion: The plaintiff's deed did not take priority over the defendant's deed, and the second appeal was rightly dismissed.

Ratio Decidendi: Where competing registered conveyances exist, priority depends on the operative intention of the parties and the facts showing whether title was intended to pass, while a registered deed may operate retrospectively under Section 47 from the date of execution if it was intended to be effective and was supported by consideration.

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