The Sub-Registrar Refused My Sale Deed Saying the Survey Number Is in the 22A Prohibited List: What Can I Do Now?

A refusal under Section 22A stops the registration, not your ownership. The sub-registrar is working from a list keyed to the survey number, so a flag says nothing yet about your deed, your chain or you. What you do next depends on one fact you probably were not given at the counter: which clause of Section 22A(1) the entry sits under and which authority put it there. Get the refusal in writing, get the extract of the list entry, and then use the removal route that matches the clause. Clauses (a) to (d) come off by an application for deletion to the authority that sent the list. Clause (e) comes off only by a government denotification, and it should never have been applied without a Gazette notification in the first place.

In short: Do not leave with an oral "it is in 22A". Ask for the written refusal order with reasons (Section 71, Registration Act, 1908) and an extract of the prohibited-list entry showing the clause. Then file for deletion with the documents that answer the reason for the listing. In Telangana, since 24 September 2026, a plot, house or flat with a valid layout or building permission can be registered through a district committee even while the entry stands. In Andhra Pradesh, the 2026 orders put the burden of proving government ownership on the government and require only the disputed portion of a survey number to stay blocked.

The sub-registrar refused my sale deed citing 22A. Does that mean the land is not mine?

No. Section 22A is a bar on registering a document. It is not a finding on title, and it does not transfer anything to the government.

The Telangana High Court said so in terms when it upheld the section in M/s. Invecta Technologies Private Limited v. State of A.P. (reported October 2023): "The Registration of a document does not create any title. The action of non-registration of a document under Section 22A does not prevent a person of the right to enjoy his property."

That cuts both ways. It is why the refusal does not take your land away. It is also why the courts have been unwilling to treat the list itself as a violation of the right to property: you still own and enjoy the land, you just cannot move it through the registration system while the entry stands. In practice lenders also generally will not accept listed land as security until the entry is cleared.

The entry attaches to the survey number, not to the owner. A single large survey number may have been part government land, ceiling surplus or under an old court order at some point. When that number is flagged, every plot carved out of it inherits the flag, including plots that were laid out, approved, sold and lived in for decades. Your registered chain describes your plot. The list describes the parent survey number. They answer different questions, which is how a clean chain and a refusal can both be true.

What should I ask for before I leave the sub-registrar's office?

Three things, in writing.

1. The refusal order with reasons. Section 71 of the Registration Act, 1908 requires every sub-registrar who refuses a document to "make an order of refusal and record his reasons for such order in his Book No. 2", endorse "registration refused" on the document, and give a copy of the recorded reasons "without payment and unnecessary delay" to anyone executing or claiming under the document.

In Telangana this is backed by a specific High Court direction. In Anantha Rameshwari Devi v. State of Telangana (W.P. No. 16799 of 2024 and batch, Justice N.V. Shravan Kumar, 9 July 2024), the court directed that the registering officer must, preferably within one week, either register the document or pass a refusal order, and that officers "shall not refuse the documents orally for registration". An oral refusal is not a refusal you can act on. Insist on the order.

2. The extract of the list entry. The Full Bench of the then common High Court in Vinjamuri Rajagopala Chary v. Principal Secretary, Revenue Department (23 December 2015) directed that if a party seeks extracts of the list, register or Gazette on the basis of which registration was refused, "it shall be furnished within 10 days from the date of an application". Apply for it the same day.

3. The clause and the source. The same Full Bench directed that the authorities who prepare the lists "shall clearly indicate the relevant clause under which each property is classified", that for clause (a) the Collector must name the statute that prohibits the transfer, and that for clause (b) the list must say which government owns the property. If the entry against your survey number shows no clause, no statute and no source, write that down. It is the first thing a Collector or a court will be asked to look at.

Also make sure your visit is recorded. The 2024 order asks sub-registrar offices to keep a watch register and asks parties to see that their presence is entered, so that nobody later says you never presented the document.

Which clause is my survey number under, and why does it decide everything?

Section 22A, as re-enacted for undivided Andhra Pradesh by A.P. Act 19 of 2007 and carried into Telangana, has five clauses, not six. The text is reproduced in the High Court's judgments. Plenty of guides, including some widely read ones, list six clauses or give "court-restricted land" a clause of its own. The statute does neither: property attached by a court sits inside clause (e).

Two consequences follow, and both are checkable.

For clauses (a) to (d), the Full Bench held that no notification is needed, and that the sub-registrar is justified in refusing so long as the list came from the authority named in the government's guidelines. It also held that a party may apply for deletion or modification and that the authority must "pass appropriate order within six weeks from the date of receipt of the application and make its copy available". A sub-registrar must not act on a list sent "directly by any authority/officer other than" those named in the guidelines.

For clause (e), Section 22A(2) requires the State Government to publish a notification "after obtaining reasons for and full description of properties furnished by the District Collectors", and the Full Bench held that this means publication in the Official Gazette. The registering authority must make a copy of that notification available on application. An application for denotification under Section 22A(4) should be decided "as expeditiously as possible and preferably within a period of three months". If your refusal is under clause (e) and nobody can produce the Gazette notification describing your property, that is the defect to press.

One honest caveat. The authority of the 2015 Full Bench is itself under question. In December 2025, while setting aside a Karimnagar Collector's cancellation of 453 registered documents on 22A land, Justice K. Lakshman of the Telangana High Court noted that later benches have taken conflicting views on whether the Full Bench ruling still holds while the validity of Section 22A is pending before the Supreme Court, and placed the papers before the Chief Justice for a possible reference to a larger bench. The directions above are still the ones the 2024 Telangana order tells registering officers to follow, but your advocate should check the current position before relying on any single line of them.

Why is a genuine private plot on the 22A list at all?

Because the lists are built survey number by survey number, and in bulk.

In Telangana this is now an admitted error and no longer just an allegation. In August 2026 the Revenue Minister said officials had forwarded the prohibited list to sub-registrars without verifying it, and that an entire survey number had been marked as government property even where only part of it belonged to the government. He gave an example a week later: Survey No. 403 in Jubilee Hills covers 1,288 acres, only two plots had an issue, and officials had placed the whole survey number on the list. On 16 September 2026 the Chief Minister told the Assembly that about 98 lakh acres remain on the list, that forest, assigned and temple lands would stay there, and that the dispute concerns about 3.7 lakh acres belonging to private individuals.

Andhra Pradesh went through the same thing earlier. Its government has said that 28 lakh acres added to the 22A list in 2022 have since been removed.

So if your land is listed, the odds that this is a records error are real. That does not change what the sub-registrar must do today. It changes how good your deletion application is likely to be.

What can I do now in Telangana?

Check whether the new fast lane fits you. On 24 September 2026 the Revenue Department issued orders allowing registration of open plots, houses and flats that are on the 22A list but hold valid layout, building or apartment permissions from GHMC, HMDA, DTCP, a municipality or another local body. You submit a link document for a transaction made after the permission was granted. District-level committees headed by the Collector, with the District Registrar and a representative of HMDA or the local body, deal with problems that arise. The Minister was explicit that properties will not be treated alike: each case is assessed on the nature of the land, the records, the permissions and any pending court matter.

If you do not fit that lane, apply for deletion. The Collector is the decision-maker, and the entry has to come off the registration department's list, because that is the one the sub-registrar reads. What decides the outcome is whether your documents answer the reason for the listing. A court-attachment entry needs the order that ended the attachment. An entry as government land needs proof that the land was private before the list existed, which means the old revenue and settlement records and an unbroken chain of registered deeds, not just the latest sale deed and passbook.

Use the channels the government has opened. A toll-free 22A helpline, 1800-599-4788, was activated in August 2026, and the Minister said registration fees collected on applications that could not be processed would be refunded. The 2024 High Court order separately directs that the refund procedure for stamp duty and registration charges on refused documents be simplified.

Know the categories. The Chief Minister's 16 September statement sorted the logjam into a 12-point plan, each strand with its own route: among them ULC surplus land, government land inside approved layouts, GO 59 and GO 118 cases, houses on assigned land, Bhoodan land, and private patta land held up over unpaid NALA conversion charges. For that last group the government said registration would be allowed once the NALA fee is paid with the stamp duty and registration charges. Houses on assigned land were sent for legal vetting, not immediate relief. Work out which strand you are in before you file.

What can I do now in Andhra Pradesh?

Two sets of 2026 decisions matter.

• 1 January 2026: five categories were taken off the prohibited list: land allotted to serving and former defence personnel, freedom fighters and political sufferers, land assigned before 18 June 1954, and private patta land. Officials were told to accept any one of about eight kinds of record (among them the 10(1) register, adangals, assignment registers, registration documents and DKT pattas) and to subdivide a survey number so that only the disputed portion stays under 22A.
• 22 July 2026: the government announced that before any property is added to the list, authorities must issue prior notice, allow 30 days for objections and 14 days for legal submissions, and pass a reasoned order. The Minister said the burden of proving that a property belongs to the government rests with the government, not the citizen, and that the Inspector General of Registration and Stamps will keep the only centralised database of prohibited properties.

If you are refused in Andhra Pradesh, cite the category you fall in, attach the one record that proves it, and if only part of your survey number is in dispute, ask in terms for subdivision and release of the rest.

Should I appeal under Section 72 or go to the High Court?

There are three routes on paper, and they suit different problems.

The statutory appeal. Section 72 gives an appeal to the Registrar against a sub-registrar's refusal, if presented within thirty days of the order. If the Registrar also refuses, Section 77 allows a civil suit within thirty days for a decree directing registration. These clocks start from the written order, which is one more reason to get it. The limit of this route in a 22A case is practical: the Registrar reads the same list. It helps where the refusal is wrong on its face, for example the wrong survey number, an entry already deleted or quashed, or a list that did not come from a competent authority. It does not remove a subsisting entry.

Deletion or denotification. This is the route that actually removes the entry, and the one the High Court expects you to use first. The 2024 Telangana order tells parties who find their property on the list to "take appropriate steps to delete the subject property from the prohibited list, in accordance with law" before coming to court.

The High Court or a civil court. The Full Bench kept both open: an aggrieved person may approach an "appropriate forum including Civil Court" for a declaration, deletion or other relief. A writ is the usual step when the deletion application is not decided in time, when a clause (e) entry has no Gazette notification behind it, or when the refusal repeats a ground the court has already rejected. The 2024 order directs sub-registrars not to insist on a fresh court order where the government order or memo they rely on has already been set aside. You are not alone in this queue: as far back as Raavi Satish v. State of Andhra Pradesh (2012) the High Court noted an alarming rise in writ petitions against registration refusals, and about 6,000 cases challenging 22A listings were reported pending in Telangana in August 2026.

Where the real dispute is that the government claims the land, a writ will not settle title. That needs the deletion authority's finding or a civil court's declaration.

I am the buyer and I have already paid an advance. What now?

Stop paying. Do not release any further amount, and do not agree to "register later, pay now".

Put your position in writing to the seller the same week: the deed was presented, registration was refused under Section 22A, and the balance is due only once the entry is removed and the deed is registered. Ask the seller to file the deletion application, because the owner holds the records that answer the listing. Fix a date after which you may take your advance back.

Do not let anyone route around the entry. In August 2026 the Telangana Revenue Minister warned that people were attempting registrations using forged government orders and memos, and that cases would be registered against those involved. The Chief Minister separately warned owners against brokers offering to "sort out" 22A issues. A deed that gets registered while the entry stands is not a solved problem. It is a new one.

If the seller knew, or the entry is one that cannot come off (genuine assigned, government, endowment or ceiling land), your remedy is recovery of the advance, and you should take advice on that quickly.

Why did a clean EC and a clean title chain not warn me?

Because they were never built to. An encumbrance certificate is compiled from registered instruments on the property. A 22A entry is not an instrument. It is a line in a separate register, keyed to a survey number, kept so that nothing gets registered. On properly listed land the registration office records nothing, so the EC is silent, and silence reads as clean.

Three habits close the gap:

1. Search the prohibited register by survey number before the advance, not before the appointment. In Telangana that means both the registration portal and the Bhu Bharati record. In Andhra Pradesh the data sits in more than one register, and a single default search can return a false clean.
2. Search the parent survey number and every sub-division, as written in the deed, the link deeds and the revenue record.
3. Repeat the search on the day of registration. Entries were added in 2026, and entries are now being removed.

This is one of the checks a LegiScore report runs as standard. For Rs. 1,999, the report reads the deed chain, the revenue record, the prohibited-property register, the litigation search and the municipal record against each other, passes through three human-review checkpoints (document analysis, missing-document review and risk acknowledgement), and grades the property from AAA to C. If your deed has already been refused, it also tells you whether the 22A entry is the only problem or the first of several, which is worth knowing before you spend three months getting it removed.

Frequently asked questions

Can the sub-registrar refuse orally and send me away? No. Section 71 of the Registration Act requires a refusal order with recorded reasons, and the Telangana High Court's July 2024 order directs that documents shall not be refused orally and that a written order should follow, preferably within a week.

How long does the authority have to decide my deletion application? The 2015 Full Bench set six weeks for applications concerning clauses (a) to (d), and "preferably" three months for a clause (e) denotification. These are court directions, not statutory deadlines, and a later bench has questioned whether the ruling still holds, so treat them as the benchmark for when to escalate.

My plot is in an HMDA-approved layout but the survey number is on the list. Do I still need deletion? Possibly not. Telangana's 24 September 2026 orders allow registration of plots, houses and flats with valid layout or building permissions, on a link document dated after the permission, with the district committee resolving problems. Eligibility is decided case by case.

The entry says assigned land. Can I get it removed? Only if the assignment law does not actually bind your parcel. Clause (a) depends on a statute that prohibits the transfer, and the list is supposed to name it. Andhra Pradesh has released land assigned before 18 June 1954. Telangana has said assigned land will stay on the list and has sent houses on assigned land for legal vetting.

Will I get my stamp duty and registration fee back? Ask for it in writing with the refusal order. The 2024 Telangana order directs that the refund procedure be simplified, and in August 2026 the Revenue Minister said fees on applications that could not be processed would be refunded.

Is there any point in appealing to the Registrar? Yes, if the refusal is wrong on its face, and only within thirty days of the order. No, if the entry is genuinely on the list, because the Registrar is bound by the same list. In that case the deletion route is the remedy.

Does 22A apply outside Andhra Pradesh and Telangana? This post covers the Section 22A enacted by A.P. Act 19 of 2007, which applies in Andhra Pradesh and Telangana. Other states have their own prohibited-property provisions with different wording, and the clause analysis above should not be carried over to them.

Sources checked on 1 October 2026: Registration Act, 1908, Sections 71, 72 and 77 (bare text); Section 22A as inserted by A.P. Act 19 of 2007, reproduced in Raavi Satish v. State of Andhra Pradesh and Vinjamuri Rajagopala Chary v. Principal Secretary, Revenue Department (Full Bench, 23 December 2015); Invecta Technologies v. State of A.P. (LiveLaw, 20 October 2023); Anantha Rameshwari Devi v. State of Telangana (LiveLaw and Verdictum, 30 July 2024); Siasat, 26 December 2025 (Karimnagar cancellations); The South First, 19 August, 17 September and 24 September 2026; Telangana Today, 24 August and 24 September 2026; Asianet Newsable, 16 September 2026; The South First, 2 January 2026 and Deccan Chronicle, 23 July 2026 (Andhra Pradesh).

Related reading: How to check if land is on the prohibited list · Prohibited properties in Telangana · Prohibited property list in Andhra Pradesh · Khata in the seller's name but the EC shows someone else · Paid a token advance and now there is a problem with the title · Property due diligence in Telangana · Property registration process in Andhra Pradesh