Unregistered property documents do not confer title or possession rights without a valid registered conveyance.

No title or enforceable right to possession of immovable property arises from an unregistered agreement to sell, power of attorney, affidavit or will; the Registration Act, 1908 and the Transfer of Property Act, 1882 require a valid registered conveyance for transfer of rights. Even a registered agreement to sell does not by itself pass title and can support only a claim for specific performance. The suit for possession and mesne profits was therefore not maintainable on the basis of these documents, and the attempt to sustain it as an action by an attorney for the true owner also failed because the plaint did not plead that basis.

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Issues: Whether title or an enforceable right to seek possession of immovable property could be claimed on the basis of unregistered agreement to sell, power of attorney, affidavit and will, and whether the suit for possession and mesne profits was maintainable on that basis.

Analysis: The Court held that no title in immovable property can pass through unregistered documents such as an agreement to sell or a general power of attorney. The statutory scheme under the Registration Act, 1908 and the Transfer of Property Act, 1882 makes compulsory registration central to the transfer of rights in immovable property. Even a registered agreement to sell does not by itself convey title and can, at best, support a claim for specific performance. The embargo created by the statute cannot be bypassed by relying on customary documents or by treating the plaintiff as having ownership rights under such instruments. The reasoning that the suit could be sustained as one filed by an attorney on behalf of the true owner was also not accepted because the plaint did not disclose such a basis.

Conclusion: The suit could not be maintained on the basis of the unregistered documents, and the decree of possession and mesne profits was unsustainable.

Final Conclusion: The appeal succeeded, the impugned judgment was set aside, and the suit stood dismissed.

Ratio Decidendi: Unregistered documents such as an agreement to sell and a power of attorney do not confer title or an enforceable right in immovable property, and possession cannot be claimed on that basis absent a valid registered conveyance or a properly pleaded agency action on behalf of the true owner.

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