Section 90: Exemption of certain documents executed by or in favour of Government

Registration Act • Official Statutory Text & Practice Guide

Statutory Regulation
Legal Standard
Competent Court / Tribunal
Act 1908

Legal Commentary & Landmark Judgments: Section 90

Section 90 exempts sanads, inam title deeds, and other crown or government grants of land from the operation of the Registration Act.

  • Government Grants Exemption: Nothing in this Act applies to: (a) sanads, inam title-deeds, and other documents purporting to be or to evidence grants or assignments by Government of land or interests in land, and (b) notices of surrender furnished by occupants to revenue officers.
  • Statutory Crown Grant Supremacy: Government land grants operate under their own statutory authority and the Government Grants Act, 1895, without requiring registration under Section 17.
Key Landmark Precedents:
  • State of U.P. v. Zahoor Ahmad, (1973) 2 SCC 547: The Supreme Court held that government grants governed by the Government Grants Act take effect according to their tenor, exempt from registration constraints under Section 90.
  • Hajee S.V.M. Mohamed Jamaludeen Bros. & Co. v. Govt. of T.N., (1997) 3 SCC 466: Affirmed that Section 90 exempts sovereign land assignments from registration formalities.
Courtroom Practice & Strategic Litigation Guidance:

In properties deriving title from pre-independence Crown Grants or Inam Sanads, absence of a registered deed does not impair title; the original Sanad operates as conclusive proof of ownership under Section 90.