The Supreme Court of India has held that a deed assigning a decree for specific performance of an agreement of sale of immovable property does not require mandatory registration under Section 17 of the Registration Act, 1908. The bench, comprising Justice J.B. Pardiwala and Justice K.V. Viswanathan , dismissed the appeal filed by the legal heirs of a judgment-debtor, affirming that such a decree does not, by itself, create any right, title, or interest in the immovable property.

Case Background

The case, titled Rajeswari & Ors. v. Shanmugam & Anr. (Civil Appeal No. 13835 of 2025), arose from an execution proceeding. The appellants are the legal heirs of a judgment-debtor against whom an ex-parte decree for specific performance was passed on September 13, 1993, in O.S. No. 100/1

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