🏠 No Ownership Through Consent Decree: Tenant Cannot Claim Title Without Registered Transfer
🛣️ Introduction Consent decrees and compromise orders are frequently used to resolve landlord-tenant disputes. However, confusion often arises when monetary settlements are mistaken as transfers of ownership. In Beena & Ors. v. Charan Das (D) Thr. LRs. (2024 INSC 680) , the Supreme Court of India decisively clarified that payment of money pursuant to a consent order in eviction proceedings does not confer ownership rights , unless there is a legally valid and registered instrument of transfer. This judgment reaffirms foundational principles of property law, rent control jurisprudence, and execution of decrees , while cautioning courts against over-interpretation of compromise orders. 🧾 Legal Framework Involved The dispute arose under the Himachal Pradesh Urban Rent Control Act, 1971 , particularly: Section 14 – Eviction on grounds such as dilapidated condition and bona fide requirement Section 21 – Appellate remedies Additionally, principles under: Transfer of Property Act, 188...