Unregistered Documents Cannot Create Security Interest to Retain Title Deeds: NCLAT Dismisses Appeal
Mr. V. Jaisankar vs Mr. Mahalingam Suresh Kumar CITATION : 2025 TAXSCAN (NCLAT) 333
The National Company Law Appellate Tribunal (NCLAT) has held that unregistered documents, including a Memorandum of Deposit of Title Deeds (MoDT), cannot create a valid security interest to retain title deeds of a corporate debtor’s property during liquidation proceedings.
Mr. V. Jaisankar, the appellant, filed a Company Appeal challenging the order of the National Company Law Tribunal (NCLT), Chennai. The NCLT had allowed an application by the Liquidator of M/s. Ganga Foundations Private Limited (the Corporate Debtor) and directed…

