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Power of attorney and property title

last updated 2026-07-21

A general power of attorney (GPA) authorises someone to act for the owner — it does not transfer ownership. The Supreme Court held in the Suraj Lamp case (2011) that title to immovable property passes only by a registered sale deed. A property being 'sold' on a GPA is a title red flag to check carefully.

What a power of attorney is — and isn't

A power of attorney lets an agent act on the owner's behalf, including signing a sale deed. It is a tool of agency, not a transfer of ownership. A common trap is a "GPA sale" — where property is handed over on a general power of attorney plus an agreement to sell, without a registered sale deed. That does not make the buyer the owner.

What the Supreme Court held

In Suraj Lamp & Industries v. State of Haryana (2011), the Supreme Court held that a GPA / agreement-to-sell / will arrangement does not convey title or create an interest in immovable property. Under the Transfer of Property Act and the Registration Act, title passes only through a registered sale deed. The court has since reiterated these limits.

The risks of a GPA transaction

Why it matters at auction

A bank auction itself transfers property through a sale certificate, not a GPA, so the mechanism is sound. But if a property's history — its chain of title — includes a GPA "sale", that is a weak link worth scrutinising, because ownership may never have passed cleanly. Spotting that kind of flag in the documents is part of the pre-bid homework AuctionScope is built to speed up. None of this is legal advice; for a high-value purchase, have the title examined by a professional.

Frequently asked questions

Can property be sold through a power of attorney?

A power of attorney can let an agent sign a sale deed, but a GPA by itself does not transfer ownership. The Supreme Court held in Suraj Lamp (2011) that title passes only through a registered sale deed.

Is a GPA sale valid in India?

A 'GPA sale' does not convey title or create an interest in the property. It is a red flag — a registered sale deed is the instrument that actually transfers ownership.

What are the risks of buying on a GPA?

You may not become the legal owner, the GPA can lapse (for example on the principal's death), and GPA chains carry a higher fraud and dispute risk. Insist on a registered sale deed.

Related terms

sale deedchain of titlesale certificateencumbrance certificate

Sources

Rates, fees and procedures change — confirm the current position on the official portals below before you act.

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Auctionscope is an information platform, not a bank, broker or legal adviser. Bank e-auctions run under the SARFAESI Act; always verify the reserve price, EMD, possession type, encumbrances and payment terms in the official sale notice and with the bank before bidding.