The Bombay High Court held that only another registered document can alter the terms of a registered sale deed, so an unregistered agreement between other parties cannot be used to say the deed's buyers still owe money or never got clean title. It discharged criminal cheating charges against purchasers who bought under a registered 2014 deed, since they were never party to the earlier unregistered arrangement the complainant relied on.
What this changes for a title check
This confirms a registered sale deed's recitals on payment and title transfer stand on their own and cannot be contradicted by an unregistered agreement, especially one the current owner was never a party to. For a title check, that means an unregistered MOU or side letter surfacing in a seller's papers, or referenced in a pending complaint, is not by itself a reason to treat a later registered deed as suspect; the registered instrument controls unless someone produces another registered document changing it. A lawyer should still note any unregistered agreement on file as background risk context, since it can still support a separate civil or criminal claim between its original parties, just not one that reaches a bona fide purchaser under the registered deed.