Supreme Court: Non-Transfer of Vehicle Registration Doesn't Invalidate Sale Transaction

Supreme Court clarifies: Non-transfer of vehicle registration doesn't nullify sale transaction. Upholds Arunachal MLA Karikho Kri's election validity in non-disclosure case. Case: Karikho Kri v. Nuney Tayang.

The Supreme Court clarified that failure to transfer vehicle registration to a new owner doesn't invalidate sale/gift transactions. This ruling came in response to a case questioning the non-disclosure of vehicles in an election affidavit, belonging to family members of Arunachal Pradesh MLA Karikho Kri.

"The Court emphasized that vehicles being goods, sale transactions are governed by the Sale of Goods Act, 1930. The conveyance of ownership occurs upon execution of sale/transfer documents, while registration by authorities is a subsequent event," noted the bench comprising Justices Aniruddha Bose and PV Sanjay Kumar.

The case revolved around whether non-disclosure of vehicles formerly owned by Kri's family members would invalidate his election, invoking Section 123(2) of the Representation of the Peoples Act, 1951.

"Reversing the Gauhati High Court's decision nullifying Kri's election, the Supreme Court ruled that non-disclosure of vehicles previously owned by Kri's dependents doesn't constitute a corrupt practice," the court emphasized.

"The Court found that the vehicles in question were either sold or gifted before Kri filed his nomination, absolving him of the obligation to disclose them. The values of these vehicles were negligible compared to Kri's declared assets," the court stated.

The Supreme Court also clarified that candidates need not disclose every movable property they own and that voters' right to know isn't absolute. "Non-disclosure by candidates won't invalidate nominations unless substantial and affecting the election outcome," the court added.

The bench highlighted that the judgment in Naveen Kumar vs. Vijay Kumar (2018) cited by the High Court was inapplicable to the current context, as it pertained to liability in motor accident compensation claims under the Motor Vehicles Act, 1988.

In response to the High Court's reliance on Naveen Kumar, the Supreme Court observed, "The judgment was specific to the Act of 1988 and not for general application."

Furthermore, the court criticized the High Court for overlooking the fact that sale transactions are governed by the Sale of Goods Act, not the Motor Vehicles Act.

The Supreme Court's ruling provides clarity on the legal implications of vehicle ownership transfers and underscores the importance of proper legal interpretation in electoral disputes.