SUNIL KUMAR ROY vs M/S. BHOWRA KANKANEE COLLIERIES LTD. & ORS.

The Supreme Court held that any document varying essential terms of a registered lease, such as the amount of rent, must be registered under the Indian Registration Act, 1908. The Court found that the appellant's reliance on an unregistered document (Exh. A-4) to prove a reduction in royalty was misplaced, as it could not alter the terms of the existing registered lease. Consequently, the appeal was dismissed, affirming the High Court's decision to decree the suit in favor of the respondent for the balance royalty claimed.