Unregistered lease deeds may prove admissions for collateral purposes, supporting title and possession when read with surrounding evidence.

Unregistered lease deeds could not be used to prove the lease as a transfer of interest, but they were admissible for the collateral purpose of proving admissions contained in them. Read with the registered sale deed, revenue records, oral testimony, and the patta standing in the appellant's name and earlier in his father's name, the evidence established the appellant's title and possession. The respondent produced no convincing evidence of original ownership. The court therefore accepted the admissions in the unregistered documents and held that the lessee was the appellant's kauldar, unable to confer better title on the respondent.

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Issues: Whether unregistered lease deeds could be relied upon to prove admissions of title and possession, and whether the appellant had established title and possession over the suit property.

Analysis: The suit turned on the probative value of unregistered lease deeds executed by the lessee's predecessor. Such documents were not admissible to prove the lease as a transfer of interest, but they could be used for collateral purposes, including proving an admission contained in the document. The evidence also showed that the patta stood in the appellant's name and had earlier stood in his father's name. The respondent produced no convincing evidence of original ownership, while the appellant supported his claim by the registered sale deed, revenue records, lease documents, and oral testimony. The admissions in the unregistered documents, read with the surrounding evidence, established that the lessee was the appellant's kauldar and could not confer better title on the respondent.

Conclusion: The appellant succeeded in proving title and possession, and the respondent's objection to the use of the unregistered lease deeds was rejected.

Ratio Decidendi: An unregistered document is inadmissible to prove the transaction itself, but it remains admissible to prove an admission contained in it for a collateral purpose.

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