Sale of real estate property requires registration of sale documents which prevents fraud of the same property being sold to multiple buyers. However, a means to avoid registration was devised and put to use in certain parts of North India. This involved creating a set of three documents - an unregistered sale deed, a Power of Attorney to the buyer from the seller and a will from the seller bequeathing the property to the buyer. The Delhi High Court considered this a ‘recognised mode of transaction.’ The Supreme Court, in the Suraj Lamp Case, brings out that unless a sale deed is registered, no interest can be created in a property.