Exemption of IBC Sale Certificates from Stamp Duty and Compulsory Registration Requirements

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Case: RAJARAM FOOD PRODUCTS INDIA LTD v. THE JOINT DISTRICT REGISTRAR AND COLLECTOR OF STAMPS NASHIK AND ORS
Court: Bombay High Court
Date: 14-07-2026
Law: Registration Act, Maharashtra Stamp Act, Insolvency and Bankruptcy Code, Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act.

Full Judgment → MCQ Test →

Highlights of the Judgment:

• Interpretation of Section 17(2)(xii) and Section 89(4) of the Registration Act regarding sale certificates.
• Analysis of whether the Insolvency and Bankruptcy Code, 2016, constitutes a "recovery Act" under the Maharashtra Amendment.
• Application of the principle that IBC is a revival mechanism rather than debt recovery legislation.
• Determination of the "Civil Officer" status of a liquidator conducting auctions under NCLT orders.
• Clarification on the distinction between filing in Book No. 1 and formal registration.
• Examination of stamp duty liability under Article 16 of the Maharashtra Stamp Act.
• Judicial reliance on precedents regarding the evidentiary value of auction sale certificates.