ROSHAN SINGH & ORS. vs ZILE SINGH & ORS.

The Supreme Court held that a memorandum of partition does not require registration under Section 17(1)(b) of the Registration Act, 1908, if it merely confirms an existing partition and does not create new rights. The Court established that partition is a continuing state of facts and does not necessitate formalities if the parties have already divided their estate. The appeal was dismissed, affirming the lower courts' findings that the document was admissible under Section 49 for collateral purposes.