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

Common questions on why a gpa or agreement to sell does not transfer property title, explained in plain terms, 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.

Typically, 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.

If you are weighing a decision on this, a short consultation can help map out the options.

This page is general information about the law in India and is not legal advice. The position can vary with the facts, so it is worth getting advice on your specific situation.