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- Validity of registration of sale deeds - Specific performance of agreements - Proof of terms of agreements - Applicability of oral agreements Analysis: The judgment dealt with four second appeals arising from four separate suits regarding the transfer of lands through sale deeds. The plaintiffs in the suits sought specific performance of the agreements. The sale deeds were executed by the defendants but were not registered due to being in the possession of a third party, Buta Ram. The plaintiffs argued that they were not at fault for non-registration as they could not compel Buta Ram to deliver the documents for registration. The court referred to previous cases like Jammu Prasad v. Md. Aftab Ali Khan and Kiam-ud din v. Rajjo to establish the importance of strict compliance with registration requirements. The court highlighted the difficulty faced by the plaintiffs in proving the terms of the agreements as the sale deeds in possession of Buta Ram could not be utilized for this purpose. Citing the case of James Skinner v. R.M. Skinner, the court emphasized that unregistered sale deeds cannot be considered as evidence of any property transaction or as a document creating a right to obtain another document. The plaintiffs' argument of proving an oral agreement made before the execution of sale deeds was rejected as such evidence was not admissible under the law. The court relied on the principle that any oral agreement regarding the terms of sale would have merged into the recorded sale deed, as per Mt. Parmeshri v. Autar Singh. Unlike the situation in A.I.R. 1926 Lah. 30, where the plaintiff was able to prove the terms of the contract, the plaintiffs in the present cases failed to establish the terms of their agreements. Consequently, the court held that the plaintiffs must fail in all four suits due to the inability to prove the terms of the agreements sought for specific performance. The appeals were dismissed, and the parties were ordered to bear their own costs in the Court.
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