The Supreme Court in Vinod Infra Developers Ltd. v. Mahaveer Lunia & Ors. reaffirmed that an agreement to sell, without a suit for specific performance, cannot confer ownership or title in immovable property. A Bench of Justices J.B. Pardiwala and R. Mahadevan held that only a registered sale deed can legally convey title under Section 54 of the Transfer of Property Act, 1882. The Court rejected the respondent’s reliance on a 2014 agreement to sell and a revoked PoA, reiterating that such documents are not conveyances. Citing Suraj Lamp and other precedents, the Court emphasized that agreements to sell cannot substitute a registered deed of conveyance.
