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Supreme Court of India 2025-05-08 allowed

Muruganandam vs Muniyandi (D) through LRS

Bench: 2 — Pamidighantam Sri Narasimha, Joymalya Bagchi

In Brief

The Supreme Court held that an unregistered agreement of sale affecting immovable property can be received as evidence in a suit for specific performance of a contract. A property owner refused to execute a sale deed despite receiving partial payment, prompting the buyer to file a suit for specific performance. The buyer sought to introduce an unregistered 2000 agreement as evidence of the oral agreement. The trial court and high court rejected it, citing non-registration and non-stamping. The Supreme Court allowed the appeal, clarifying that the proviso to Section 49 of the Registration Act, 1908 permits unregistered documents to be tendered as proof of oral agreements in specific performance suits, provided they are endorsed appropriately.

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Civil Procedure Evidence Registration of Documents Specific Performance Immovable Property Documentary Evidence

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