The Supreme Court reaffirmed that an agreement to sell is not the same as a conveyance, meaning it does not transfer any right, title, or ownership in property unless followed by a registered sale deed and a suit for specific performance under the Transfer of Property Act, 1882.

In the case Vinod Infra Developers Ltd. v. Mahaveer Lunia & Ors. (2025 LiveLaw (SC) 630), the bench of Justices Pardiwala and Mahadevan clarified:

• The respondent had an unregistered agreement to sell and power of attorney, which were revoked.
• Despite executing sale deeds and getting the property mutated (2022), the court held that without a registered conveyance deed and a suit for specific performance, the agreement couldn’t create any transferable interest.
• As per Section 54 of the TPA and precedents like Suraj Lamp & Industries v. Haryana (2012), unregistered agreements don’t confer title or interest
• The Court emphasized that only a registered sale deed can convey ownership.

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