Why a GPA or Agreement to Sell Does Not Transfer Property Title: Frequently Asked Questions

This page sets out, in general terms, how common questions on why a gpa or agreement to sell does not transfer property title works under Indian law.

Before the frequently asked questions

In Ramesh Chand v Suresh Chand (1 Sep 2025), the Supreme Court reaffirmed its earlier ruling in Suraj Lamps: an agreement to sell, a General Power of Attorney, and a will, taken together or separately, do not transfer ownership of immovable property.

As a general rule, ownership of immovable property transfers only through a registered conveyance (typically a registered sale deed), except in specific statutory exceptions.

Frequently asked questions

Can I become the owner of a property through a General Power of Attorney and a will?

No. The Supreme Court has repeatedly held, most recently in Ramesh Chand v Suresh Chand (1 Sep 2025), that a GPA, an agreement to sell, and a will do not transfer ownership. A registered sale deed is generally required.

For a fuller explanation, see Registration Is Not the Same as Clear Title, Documents to Review Before Buying Property, and Property Title Verification in India: What Due Diligence Covers.

Where this applies to a live matter, it is usually worth discussing it in a consultation before acting.

This overview is general information, not legal advice. Procedures and local practice can differ, so a specific review of your matter is advisable before acting.