# Rajaram Food Products India Limited vs. The Joint District Registrar (Class-1) and Collector of Stamps, Nashik and others

> HC judgment dated 2026-07-14. Citation: TCN-2026-HC-00028. The petitioner, an auction purchaser, acquired property of a corporate debtor (M/s. Gonglu Agro…

- **Court:** HC
- **Order date:** 14 Jul 2026
- **Citation:** TCN-2026-HC-00028
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/bombay-high-court-panaji/rajaram-food-products-india-limited-vs-the-joint-district-registrar-tok6w

## Summary

### Background

The petitioner, an auction purchaser, acquired property of a corporate debtor (M/s. Gonglu Agro Pvt. Ltd.) through an e-auction conducted by a liquidator under the Insolvency and Bankruptcy Code (IBC). A sale certificate was issued to the petitioner. Respondent No.1, the Joint District Registrar, subsequently ordered the petitioner to pay stamp duty on this sale certificate, citing Article 16 of Schedule I of the Stamp Act. The petitioner challenged this order, arguing that under Section 89(4) and Section 17(2)(xii) of the Registration Act, and in light of Supreme Court precedents, such a sale certificate is not compulsorily registrable and does not attract stamp duty, requiring only filing in Book No.1.

## Facts

Rajaram Food Products India Limited (petitioner) is an auction purchaser.

The petitioner purchased immovable property of M/s. Gonglu Agro Pvt. Ltd. (corporate debtor) in an e-auction held on 30.12.2024.

M/s. Gonglu Agro Pvt. Ltd. underwent Corporate Insolvency Resolution Process (CIRP), which failed, leading to liquidation by an NCLT, Chennai order dated 05.01.2024.

Respondent No.5 was appointed as liquidator for M/s. Gonglu Agro Pvt. Ltd.

A sale certificate dated 30.01.2026 was issued in favour of the petitioner after depositing the entire consideration.

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## Issues and analysis

### Issue 1: Whether a sale certificate issued to an auction purchaser in pursuance of an auction sale conducted …

**Ratio:** A sale certificate issued in a public auction by an authorized officer (including a

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**Reasoning:** The Supreme Court, in cases like State of Punjab vs. Ferrous Alloy Forgings P. Ltd., has

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**Interpretation:** Section 17(2)(xii) of the Registration Act specifically exempts "any

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**Application:** The sale certificate in the present case was issued to the petitioner as an

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## Parties

- **Judges:** MANISH P…; SHREERAM V.…
- **Appellants:** Rajaram Food…
- **Respondents:** M/s. Gonglu Agro…; The Joint…; +4 more
- **Advocates:** Abhinav Chandrachu…; Darshan Pa…; +5 more

## Timeline

- **2024-01-05 — Liquidation…**: The National Company Law Tribunal (NCLT), Chennai, directed the liquidation of M/s.…
- **2024-12-30 — E-auction…**: An e-auction was held for the immovable property of the corporate debtor, where the…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 89(4) — Replacement of resolution professional](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-89)

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