4 Transfer of Land Property without Registration of Deed

The doctrine (the Supreme Court's long-settled middle path — the syllabus's closing question):1. The rule: an unregistered deed of immovable property does not transfer ownership — the sale on a mere likhat (the private writing) leaves the registered title where it was: ownership does not pass, and the "buyer" cannot claim the lalpurja against the seller's subsequent registered sale to a third party (the registry's integrity — the third party's registered title prevailing);2. But the obligations survive: the unregistered deed is not a nullity between the parties — the buyer's paid price and taken possession generate enforceable contractual obligations (the seller's duty to execute and register; the restitution of the price on failure) within the limitation period — the Court's equity channeled through contract, not property;3. Possession's consequences: the long possessor under the likhat protected against the seller's eviction (the possession-protection of Unit 2) though not crowned with title; conversely, the seller's re-sale-plus-registration to another exposes him to damages/fraud actions — the double-dealing's remedies;4. The exceptions' edges: the court-decree transmissions (the decree operating without a deed); the inheritance's namasari (succession operating by law); the family-partition entries; the benami transactions' separability (the benami's beneficiary-versus-name doctrines);5. The practice warning: the rural reality — decades of likhat-transactions (the informal market) — the titling gap the Court's doctrine tolerates but cannot cure: the remedy…