Arbitration award on dissolved partnership assets need not be registered when it only apportions existing partner shares.

An arbitration award distributing the residue of a dissolved partnership firm among the partners did not require registration under section 17 of the Registration Act, 1908. The award only apportioned assets after settlement of accounts; it did not create or transfer any fresh right in immovable or movable property, because the partners were already entitled to the firm assets to the extent of their shares on dissolution. The allocation was therefore not a conveyance, partition, or extinguishment of rights attracting compulsory registration. The principle in S.V. Chandra Pandian was applied, and the objection to enforceability on registration grounds failed.

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Issues: Whether an arbitration award distributing the residue assets of a dissolved partnership firm among the partners requires registration under section 17 of the Registration Act, 1908.

Analysis: The award merely apportioned the assets of the dissolved firm among the partners according to their shares after settlement of accounts. On dissolution, the partners were already the real owners of the firm assets to the extent of their shares, and the allocation of assets to each partner did not create or transfer any fresh right in immovable or movable property. Such distribution was not a conveyance, partition, or extinguishment of rights attracting compulsory registration. The earlier decision in S.V. Chandra Pandian was applied, and the decision relied upon by the respondents was distinguished as not governing the present situation.

Conclusion: The award did not require registration under section 17 of the Registration Act, 1908, and the objection to its enforceability on that ground failed in favour of the appellants.

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