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Issues: Whether the period during which a court order restrained the parties from proceeding with registration was to be excluded while computing the time for presenting an award for registration under the Registration Act, and whether the registration made after the expiry of the prescribed period was valid.
Analysis: The prescribed period under Section 23 of the Registration Act is four months, with a further extension of four months permissible under Section 25 in limited cases. The Registration Act does not expressly provide for extension or exclusion of time in circumstances where compliance is prevented by a subsisting judicial order. However, the principles that a litigant should not be prejudiced by an act of the court and that the law does not compel the impossible apply unless excluded by statute. The period during which registration was restrained by the court order was therefore liable to be excluded in computing the prescribed time. Even after excluding that period, the award was still presented far beyond the permissible limit.
Conclusion: The registration officer had no authority to admit the award to registration, the registration was invalid and ineffective, and the petitioner succeeded.
Ratio Decidendi: Where compliance with a statutory time limit for registration is prevented by an operative court order, the restrained period is to be excluded in computing time, but registration remains invalid if the document is still presented beyond the permissible period after such exclusion.