Registered Sale Deed Cancellation: administrative power ends after registration, and fraud disputes must be resolved by civil court.

The Registration Act, 1908 was treated as a complete code for registration, and the registering authority was held to have no power to cancel or set aside a registered sale deed after registration, even where fraud or impersonation is alleged. In the absence of an express statutory provision or valid rule, administrative action could not annul a completed conveyance, and Article 162 could not override the statute. Disputes raising fraud, title, or the validity of competing sale deeds were held to require evidence and adjudication by a competent civil court, so writ interference was declined.

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Issues: (i) Whether, after registration, the registering authority can cancel or set aside a sale deed on allegations of impersonation or fraud. (ii) Whether such a dispute must be left to adjudication before a competent civil court and whether writ interference is warranted.

Issue (i): Whether, after registration, the registering authority can cancel or set aside a sale deed on allegations of impersonation or fraud.

Analysis: The Registration Act, 1908 was treated as a complete code for registration, and the statutory scheme was read as confining the registering officer to the pre-registration enquiry. The provisions dealing with presentation, enquiry, admission or denial of execution, endorsement, refusal, and penalties did not confer power to annul a document after registration. In the absence of an express statutory provision or valid rule, an executive order could not authorise the registering authority to withdraw registration or cancel a registered deed. The power under Article 162 could not override the statute or deprive a person of property without authority of law. The Court adopted the reasoning that fraud allegations do not enlarge administrative power to cancel a registered conveyance.

Conclusion: The registering authority has no power under the Registration Act, 1908 to cancel or set aside a registered sale deed, even where fraud or impersonation is alleged.

Issue (ii): Whether such a dispute must be left to adjudication before a competent civil court and whether writ interference is warranted.

Analysis: The Court held that questions involving fraud, title, and the validity of competing sale deeds require adjudication on evidence before a civil court. The available civil remedy was treated as the proper course for challenging the underlying transaction or the validity of the instrument. On the facts, the later registered sale deed was executed after an earlier registered sale deed in favour of another purchaser, and interference under Article 226 would have restored an illegality. Discretionary writ jurisdiction was therefore declined.

Conclusion: Yes. The dispute lies within the domain of the civil court, and writ interference was not justified.

Final Conclusion: The reference was answered against administrative cancellation of a registered sale deed, and the writ petition failed, leaving the petitioner to pursue civil remedies.

Ratio Decidendi: In the absence of an express statutory provision or valid rule, a registering authority cannot cancel or annul a registered sale deed on administrative grounds, even on allegations of fraud or impersonation; such disputes must be agitated before a competent civil court.

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