An agreement to sell cannot be treated on par with a sale deed and does not convey title to the property in view of Section 54 of the Transfer of Property Act, 1882 (TPA).
The Court also opined that the GPA and the Will executed by the seller cannot be recognized as documents of title or documents conferring a right in the immovable property, as no action in furtherance of the GPA has been taken and the Will has not yet come into force.