Registered lease deed prevails over unregistered framework agreement, limiting reliance on collateral purposes for immovable property rights.

An unregistered framework agreement concerning immovable property could not be used to vary, override, or extinguish rights created by a later registered lease deed and registered modification deed. Where registration is compulsory, such an instrument cannot affect immovable property or serve as substantive evidence of the transaction except for limited collateral purposes. The registered lease instruments therefore governed the parties' rights, including the termination terms, and the unregistered agreement could not be relied on to establish lease conditions or to exclude the land from the insolvency process. The requested exclusion of the subject property was accordingly rejected.

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Issues: Whether the unregistered Framework Agreement could be relied upon to determine the leasehold rights over the subject land and to exclude the land from the corporate insolvency resolution process, or whether the registered Lease Deed and subsequent registered Modification Deed governed the parties' rights.

Analysis: The Framework Agreement was an unregistered document and could not, by itself, create, limit, or extinguish rights in immovable property where the later registered Lease Deed covered the same land and the parties. Under the Registration Act, 1908, documents compulsorily registrable cannot affect immovable property or be received in evidence of the transaction except for limited collateral purposes. The Transfer of Property Act, 1882 requires a lease for more than one year to be made by registered instrument, and the registered Lease Deed, as modified, contained the operative terms governing the lease, including termination. The Framework Agreement was not mentioned in the subsequent registered instruments and could not be used to override the registered documents or to establish termination of the lease on insolvency. The unregistered instrument also could not be relied upon as substantive evidence for the asserted lease conditions.

Conclusion: The Framework Agreement could not be looked into to determine the lease or to exclude the subject property from the insolvency process, and the application was liable to be dismissed.

Final Conclusion: The operative lease arrangement was held to be controlled by the registered instruments, not the earlier unregistered agreement, and the requested exclusion of the land from the insolvency process was rejected.

Ratio Decidendi: An unregistered instrument concerning immovable property cannot be used to alter or displace the terms of a later registered lease deed, except for limited collateral purposes; where registration is compulsory, the registered instrument governs the legal rights.

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