ORDER : 1. This writ petition has been filed challenging the impugned refusal check slip dated 01.03.2025 issued by the 2 nd respondent and for a consequential direction to the 2 nd respondent to admit and register the documents presented by the petitioners with respect to the subject property. 2. Heard Mr. N.L. Rajah, learned Senior Counsel for the petitioners Mr.U.Baranidharan, learned Special Government Pleader for R1 & R2 and Mr. N.R.R. Arun Natarajan, learned Special Government Pleader for R3. 3. The dispute between the petitioners and the 3 rd respondent Temple was considered in detail in the earlier writ petition filed in WP.No.21362 of 2024, which was disposed of by an order dated 13.02.2025. The crux of the issue that was dealt with in the said writ petition is covered at paragraph 7 and 8 of the order which is extracted hereunder: 7 . In the case in hand, survey Nos.56, 57/1, 57/2A & 70/1 are involved and they measure a total extent of 2.76 acres. Even in the year 2007, when the first petitioner started developing the subject properties, a legal notice came to be issued by the third respondent temple on 27.6.2007. At that point of time, the third respondent temple was not claiming any right with respect to survey Nos.56, 57 & 70. On receipt of the said notice, a reply notice dated 03.7.2007 was issued by the first petitioner whereby it was informed that the properties belonging to the third respondent temple have not been utilized for the purpose of putting up a residential construction. 8 . That apart, in respect of survey No.90, over which, the third respondent is claiming a right, the first petitioner, through the letter dated 25.1.2009, requested the Commissioner, Hindu Religious & Charitable Endowment Department, Chennai-34 for giving on lease an extent of 20 cents in order to utilize the same as one of the approach roads to the subject properties. There were some exchange of correspondence and in order to show their bona fides, the first petitioner also paid a sum of Rs.50 lakhs as donation to the third respondent temple. There was no further development thereafter. The petitioner obtained necessary planning permission and the building licence and completed the project after getting a completion certificate on 14.2.2014. Thus, 952 residential units have been put up over the entire area. There was no further development thereafter. The petitioner obtained necessary planning permission and the building licence and completed the project after getting a completion certificate on 14.2.2014. Thus, 952 residential units have been put up over the entire area. In so far as the title to the subject properties is concerned, the petitioners are claiming title for all the three survey numbers through various title documents and pattas were also standing in the names of the private individuals. 4. This Court after considering the entire facts and circumstances of the case and also the orders passed by the District Revenue Officer confirming the order passed by the Revenue Divisional Officer, allowed the writ petition in the following terms: 19. Accordingly, the orders dated 23.5.2023 and 24.3.2020 passed by respondents 1 and 2 respectively are hereby quashed. As a consequence, the second respondent shall restore the pattas as they stood originally in the names of the private individuals forthwith. The matter is remanded back to the second respondent, who shall issue notice to the petitioners and the third respondent temple, give them an opportunity and pass a speaking order by assigning proper reasons within the ambit of the Act and the Rules framed thereunder. This Court intentionally has not gone into the merits of the case nor rendered any finding since it will have a bearing while the matter is dealt with by the second respondent. The second respondent shall pass final orders within a period of three months from the date of receipt of a copy of this order. It is made clear that any observations made by this Court in this order will not have any bearing while the second respondent decides the issue. The second respondent is directed to independently consider the claims made by both the parties and thereafter pass final orders. 5. It is brought to the notice of this Court that the enquiry is yet to commenced and in the meantime, the petitioners submitted documents for registration before the 2 nd respondent. The same was refused to be entertained and registered by the 2 nd respondent on the ground that the property belonged to the HR & CE Department and if the same is entertained, it will be in violation of Section 22A (1)(ii) of the Registration Act . 6. The same was refused to be entertained and registered by the 2 nd respondent on the ground that the property belonged to the HR & CE Department and if the same is entertained, it will be in violation of Section 22A (1)(ii) of the Registration Act . 6. This Court has carefully considered the submissions made on either side and the materials available on record. 7. The substantiative dispute between the petitioners and the 3 rd respondent Temple is going to be decided by the concerned authority pursuant to the earlier orders passed in WP.No.21362 of 2024. In the meantime, this Court also directed that the patta must be restored to its original position in the names of the private individuals. Under such circumstances, the only issue is as to whether the petitioners must be stopped from registering the documents till a final decision is taken by the authority. 8. The crux of the issue that is involved in the present writ petition pertains to the stand taken by the 2 nd respondent to the effect that the property belongs to the Temple and therefore it cannot be registered. Such stand taken by the 2 nd respondent may not be sustainable in view of the earlier order passed in WP.No.21362 of 2024. 9. The learned Special Government Pleader appearing on behalf of the 3 rd respondent Temple submitted that if pending the proceedings before the concerned authority, third party rights are created, the Temple will be put to hardship and the subsequent purchasers will start claiming right over the property and the very purpose of remaining the matter back to the authorities will stand defeated since the petitioners will wash of their hands and move from the scene and the purchasers will get into the scene and they will start claiming themselves to be the bona fide purchasers. In view of the same, the learned Special Government Pleader contended that no registration must be allowed till the authority completes the enquiry and passes orders pursuant to the earlier order passed in the earlier writ petition. 10. In reply to the above submission, the learned Senior Counsel for the petitioners submitted that the 2 nd respondent cannot go into the title dispute between the petitioners and the 3 rd respondent. 10. In reply to the above submission, the learned Senior Counsel for the petitioners submitted that the 2 nd respondent cannot go into the title dispute between the petitioners and the 3 rd respondent. He further submitted that such a power that was available for the 2 nd respondent by virtue of Rule 55A (1) of the Registration Rules is no longer available by virtue of the order of the Apex Court in Civil Appeal No.3954 of 2025, dated 07.04.2025. The learned Senior Counsel further placed reliance upon the order of the learned Single in WP.No.11056 of 2024 dated 26.04.2024 and he specifically relies upon paragraphs 19-22 in the said order which is extracted hereunder: 19. Section 22-A authorizes the refusal in three types of cases: (i) where the land belongs to the State Government or local authorities (ii) belongs to any endowment covered by the T.N Hindu Religious and Charitable Endowments Act, 1959 (iii) land which is donated for BhoodanYagna vested in the Tamil Nadu State Bhoodhan Yagna Board (iv) or is a property belonging to a Waqf which is under the superintendence of the Waqf Board under the Waqf Act, 1995. Without any prior sanction issued by the competent authority provided under the Religious Act or by any authority authorised by the State Government for this purpose, the Sub-Registrar cannot refuse the registration. The second category under Section 22-A (2) relates to the transfer of ownership of lands converted to house sites without permission for the development of such land by the planning authority. In such cases, the only exception is where it is shown that the same house site is previously registered as a house site, in which case there is no bar for registration. The third category under Section 22-A (3) is where the Registrar can refuse to register a unilateral cancellation of a sale deed. 20. It is relevant to note that many registration has been refused citing Section 22-A on the only ground that some requests are made by Hindu Religious and Charitable Endowments Board or the Waqf Board. The third category under Section 22-A (3) is where the Registrar can refuse to register a unilateral cancellation of a sale deed. 20. It is relevant to note that many registration has been refused citing Section 22-A on the only ground that some requests are made by Hindu Religious and Charitable Endowments Board or the Waqf Board. It is relevant to note that the Division Bench of this Court in the case of Sudha Ravikumar v. The Special Commissioner, AIR 2017 Mad 203 , wherein, it is held as follows: “the registering authority is not bestowed with any quasi judicial function to hold a roving enquiry in respect of the title to the property. But he has to hold a summary enquiry for the limited purpose of satisfying himself that the document deserves to be registered. Such enquiry is neither judicial nor quasi-judicial.” 21. Similarly, this Court in the case of D. Kalaiyarasan v. Inspector General, 2018 SCC Online Mad 7224 , it was held that unless and until the authority has clinching materials to show that the property belonged to the religious institution, the registration cannot be refused. Also, this Court in the case of G. Rajasulochana v. Inspector General made in W.P. No. 29706 of 2024 dated 16.04.2024 , it was observed as under: “If there is a serious dispute on the title to the land, such questions cannot be decided by the Registrar at the stage of registering a document since he is only conducting a limited summary enquiry.” 22. Therefore, this Court is of the view that merely on the basis of some letters without production of title deed clinchingly establish the title of the Waqf Board and religious institutions mere citing some objections in the form of letters, document cannot be refused to be registered. 11. The learned Senior Counsel submitted that it is not as if the petitioners are going to sell away the entire property and move away from the scene. What is proposed to be sold is only a small proportion of undivided share and therefore, the petitioners will effectively participate in the proceedings before the concerned authority who is yet to commence the enquiry in this case. 12. In the considered view of this Court, the dispute between the petitioners and the 3 rd respondent Temple is not within the realm of enquiry before the 2 nd respondent. 12. In the considered view of this Court, the dispute between the petitioners and the 3 rd respondent Temple is not within the realm of enquiry before the 2 nd respondent. Already this Court has directed the concerned authority to take a decision within a time frame and the enquiry is yet to commence. This Court has also directed the patta to be restored to its original position in the name of the private individuals. Hence, there cannot be any bar for the petitioners dealing with the property. However, in order to safeguard the interest of the Temple, such permission can be granted to the petitioners subject to two conditions and they are; (a) the purchaser of the property will be subject to the final result in the proceedings that is going to be conducted by the concerned authority pursuant to the earlier order passed by this Court in WP.No.21362 of 2024, dated 13.02.2025. (b) The petitioners shall ensure that the proceedings before the Revenue Divisional Officer is effectively conducted and the earlier order passed in WP.No.21362 of 2024, is properly complied with. 13. The above safeguards will sufficiently take care of the interest of the Temple. Hence, the impugned refused check slip issued by the 2 nd respondent dated 01.03.2205, is hereby quashed and there shall be a direction to the 2 nd respondent to register the documents presented by the petitioners, if it is otherwise in order. 14. In the result, this writ petition is allowed in the above terms. No costs.