Suraj Lamp Judgment
The Supreme Court judgment in Suraj Lamp & Industries Pvt. Ltd. vs. State of Haryana, (2012) 1 SCC 656, delivered on 11 October 2011 (the "2012" suffix is the report year, not the judgment year). The Court held that sale of immovable property through General Power of Attorney + Agreement to Sell + Will is not a valid mode of conveyance — only a registered sale deed effects transfer. DeedSure flags GPA-based sales executed after 11 October 2011 as CRITICAL severity, and pre-judgment GPA sales as HIGH severity.
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