MANGAN LAL DEOSHI vs MOHAMMAD MOINUL HAOQUE & OTHERS.

The Supreme Court held that an agreement for a lease must create a present and immediate interest in land to be considered a 'lease' under the Indian Registration Act, 1908, specifically under Section 17(1)(b) and (d). The Court ruled that a compromise decree creating a contingent underlease, dependent on the payment of a sum to a third party, does not constitute a lease as it does not effect an immediate demise. Consequently, the decree was deemed exempt from registration under Section 17(2)(vi).