The Supreme Court on Friday delivered a judgment that could reshape how property transactions are recorded and verified in India. The ruling came in Civil Appeal tagged with Diary No. 12674/2024 and Diary No. 18064/2024. The case, Samiullah v. State of Bihar and Others, was heard by a Bench of Justices PS Narasimha and Joymalya Bagchi.
The Bench directed the Law Commission of India to examine how blockchain technology can be used to modernise the country’s property registration regime and move toward a conclusive titling system. The judges said the time had come to simplify the buying and selling of land and bring the law in line with technological developments.
The Court highlighted the long-standing divide between registration and ownership under Indian law. Registration only creates a public record but does not certify ownership, which forces buyers to trace title through old documents. The judgment noted that nearly two-thirds of civil litigation in India involves property disputes, a sign of how the current system burdens ordinary citizens.
The Bench said blockchain technology could help close this gap. It pointed to the technology’s ability to create secure, transparent and tamper-proof records and suggested that cadastral maps, survey data and revenue records could be integrated into a single verifiable framework. Such a system, the Court said, could make land transactions more reliable and publicly accessible.
To achieve conclusive titling, the judges said the Centre may have to revisit and harmonise several laws, including the Transfer of Property Act, 1882, the Registration Act, 1908, the Indian Stamp Act, 1899, the Evidence Act, 1872, the Information Technology Act, 2000 and the Data Protection Act, 2023. A unified framework, they said, would support transparency and trust in property records.
The appeals concerned amendments to Rule 19 of the Bihar Registration Rules, 2002. These amendments allowed registering authorities to refuse registration if the seller failed to produce proof of mutation in their name. The Court struck down the amendments, holding that they imposed a requirement not found in the Registration Act. It also noted that Bihar’s survey and settlement process is still incomplete, making the rule impractical.
The Bench said the ability to freely acquire and transfer immovable property is tied to the constitutional right to own property. It questioned whether the country should now move toward a system where registration itself serves as conclusive proof of ownership backed by the State.
Senior Advocate Manan Kumar Mishra and Advocate A Velan appeared for the appellants. Senior Advocate Ranjit Kumar, assisted by Advocate Manish Kumar, represented the State of Bihar.
