Limited registration power: prior agreement for sale does not prevent later transfer, and refusal must rest on statutory grounds.

A prior registered agreement for sale does not, by itself, bar the owner from executing and presenting a later transfer deed for the same immovable property. The registering authority's enquiry is limited to the statutory grounds under the Registration Act, the Tamil Nadu amendment provisions, and the Registration Rules, such as defects in language, alterations, description, appearance, or denial of execution. Because an agreement for sale creates no interest or charge in the property, later transfers are not prohibited by law, though they remain subject to earlier civil rights already created. Registration is a mechanism for public notice, not for deciding title or competing claims.

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Issues: Whether a prior registered agreement for sale bars the owner from executing and presenting a subsequent transfer document for the same immovable property, and whether the registering authority can refuse registration on that ground except where refusal is authorised by the Registration Act and the Tamil Nadu amendment provisions.

Analysis: The Registration Act was held to confer only a limited power of enquiry on the registering officer, confined to statutory grounds such as language, alterations, insufficient description, non-appearance, denial of execution, and the specific refusal categories under the Tamil Nadu amendment and the Registration Rules. An agreement for sale, by its nature under the Transfer of Property Act, does not create any interest or charge in the property, and successive transfers are not prohibited by law; later transfers merely remain subject to earlier rights already created. The Court distinguished the earlier view that registration of an agreement for sale disables all later dealings, holding that such a view is inconsistent with the statutory scheme and with the principle that registration is meant to give public notice rather than to adjudicate title or validity of competing civil rights.

Conclusion: A prior registered agreement for sale does not bar subsequent transfers of the same property, and the registering authority cannot refuse registration on that basis except in the limited situations expressly permitted by law.

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