Section 84: Registering officers to be deemed public servants

Registration Act • Official Statutory Text & Practice Guide

Statutory Regulation
Legal Standard
Competent Court / Tribunal
Act 1908

Legal Commentary & Landmark Judgments: Section 84

Section 84 declares registering officers to be public servants within the meaning of the Indian Penal Code, and accords official proceedings the character of judicial proceedings for contempt and perjury.

  • Public Servant Status: Every registering officer shall be deemed to be a public servant within the meaning of the Indian Penal Code (and corresponding BNS provisions).
  • Judicial Proceeding Deeming: All official inquiries under the Act are deemed judicial proceedings within the meaning of Section 193 and Section 228 IPC.
  • Perjury & Contempt Protection: False evidence tendered before a registering officer invites criminal prosecution under Section 193 IPC; intentional insult or interruption is punishable under Section 228 IPC.
Key Landmark Precedents:
  • State of Gujarat v. Manshankar Prabhashankar Dwivedi, (1972) 2 SCC 392: The Supreme Court held that statutory deeming clauses conferring public servant status impose strict anti-corruption duties under the Prevention of Corruption Act.
  • Veena Singh v. District Registrar, (2022) 7 SCC 1: Affirmed that registration inquiries under Section 74 are judicial proceedings governed by Section 84.
Courtroom Practice & Strategic Litigation Guidance:

Statements made before the Sub-Registrar or Registrar in formal inquiries carry the full legal gravity of court depositions; tender only verified, documentary evidence.