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Unregistered assignment deed may support substitution for collateral purpose, while validity objections remain open for final adjudication.

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Full Text of the Document

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....An unregistered assignment deed was treated as sufficient prima facie basis for substitution of the assignee in proceedings, because permitting the assignee to contest the matter was considered a collateral purpose distinct from determining the deed's validity or transfer effect. Relying on the principle that an unregistered document may be read for a collateral purpose, the Tribunal left all objections under Sections 17 and 49 of the Registration Act open for decision in the main company petition. The substitution of the assignee was therefore maintained, while the challenge to the assignment deed's admissibility, enforceability and legal effect was reserved for final adjudication.....