Registration Act limits registering authority's power to refuse unilateral cancellation deeds; larger-Bench review was indicated.

Under the Registration Act, 1908, a registering authority's role is administrative and, absent an express statutory rule, does not extend to adjudicating title disputes or cancelling a registered instrument merely because an earlier transfer is alleged to be unilateral or void. The majority noted that comparable State rules requiring bilateral execution and notice were absent, and declined writ interference with the High Court's refusal of relief, while stating that the broader validity of unilateral cancellation of registered deeds should be examined by a larger Bench. The dissent would have treated a unilateral extinguishment deed as void ab initio and quashed the later conveyances.

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Issues: Whether a registering authority under the Registration Act, 1908 can cancel or refuse to register a deed of extinguishment or cancellation of a previously registered conveyance on the ground that the earlier transfer was unilateral and void, and whether the impugned documents could be set aside in writ proceedings.

Analysis: The majority opinion examined the scheme of the Registration Act, 1908, including the compulsory registration provisions, the registerer's limited role in scrutiny before registration, and Section 69 power to frame rules. It distinguished authorities holding that unilateral cancellation of a sale deed is void where specific rules require bilateral execution and notice, and noted that in the absence of a comparable rule in the State concerned, the statutory text did not clearly confer power on the registering authority to adjudicate title disputes or cancel registered instruments. The majority also noted that the parties had already taken the dispute before cooperative society forums and that related proceedings were pending.

Conclusion: The majority held that the matter did not warrant interference with the High Court's refusal to grant the writ relief, and that the broader proposition regarding unilateral cancellation of registered deeds required consideration by a larger Bench.

Concurring Opinion: V. Gopala Gowda, J. dissented and held that a unilateral extinguishment deed cancelling an earlier absolute sale deed was void ab initio, that the registering authority had no jurisdiction to register it, and that the subsequent sale deeds were liable to be quashed. The dissent relied on the Specific Relief Act, 1963, the Limitation Act, 1963, and the constitutional protection of property, and would have allowed the appeal.

Final Conclusion: The Bench did not produce a single operative majority on the merits of the cancellation dispute; the matter was treated as needing larger-Bench consideration on the legal proposition while the dissent would have granted complete relief.

Ratio Decidendi: In the absence of an express statutory rule authorising unilateral cancellation, the registering authority's role under the Registration Act is administrative and does not extend to adjudicating title disputes or cancelling registered instruments.

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