Unregistered sale agreement cannot support insolvency property claims without registered conveyance or proved possession.

Claims based on an unregistered agreement for sale concerning immovable property could not be enforced in insolvency proceedings without a registered conveyance or proof of possession. Because Section 17 and Section 49 of the Registration Act, 1908 and Section 54 of the Transfer of Property Act, 1882 barred reliance on the unregistered document to establish title or contractual rights in the property, the demands for property tax reimbursement, maintenance, common facilities, office accommodation, and execution of sale deeds were not treated as legally due debts. The execution of sale deeds was also characterised as a civil dispute outside insolvency claims. The rejection of the claims was sustained, except for the corpus fund balance already admitted.

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Issues: Whether claims founded on an unregistered agreement for sale, in the absence of a registered sale deed and proof of possession, could be admitted in corporate insolvency resolution proceedings, and whether the rejected claims for property tax reimbursement, maintenance, common facilities, office accommodation, and execution of sale deeds were sustainable.

Analysis: The claim was traced to an unregistered agreement for sale concerning immovable property. A document required to be registered under Section 17 of the Registration Act, 1908 cannot be received as evidence of the transaction or used to enforce rights in the property unless registered, by reason of Section 49 of the Registration Act, 1908. The agreement did not establish a valid conveyance or transfer of title within Section 54 of the Transfer of Property Act, 1882, and no registered sale deed or proved handing over of possession was shown. On that footing, the asserted reimbursement of property tax for an alleged office space, expenses towards integrated building management systems, maintenance, exhaust pipes, diesel generator fittings, and permanent office accommodation were held not to be debts legally due. The claimant also failed to discharge the burden of proving admissible claims under the insolvency regulations, and the demand for execution of sale deeds was held to be a civil dispute, not a claim enforceable in insolvency proceedings. The only admitted amount remained the corpus fund balance already accepted by the resolution professional.

Conclusion: The impugned rejection of the claims was sustained, and the appeal failed.

Ratio Decidendi: Claims over immovable property and consequential monetary demands cannot be enforced in insolvency proceedings on the strength of an unregistered agreement for sale unless a registered conveyance and resulting legal right are established.

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