Reviewed case brief

Suraj Lamp and Industries Pvt Ltd v State of Haryana

(2012) 1 SCC 656

GPA-based transactions (General Power of Attorney + Agreement to Sell + Will) do not convey title to immoveable property. Only a registered sale deed under S.54 TPA transfers ownership.

property-lawGPAsale-deedregistrationsection-54
Court
Supreme Court of India
Year
2012
Subjects
Property Law
Reviewed
2026-06-30

Rule established

Transfer of immoveable property only by registered sale deed; GPA transactions do not convey title

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        (2012) 1 SCC 656

        Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.