The expression "title" conveys different forms of right to a property, which can include a right to possess such property

 In the Matter of Nagen Hazarika (Deceased) ... vs Smt. Manorama Sharma AIR 2007 Gau 62 it was held by the Gauhati High court that "Title" is a broad expression in law, which need not always be understood as akin to ownership. The expression "title" conveys different forms of right to a property, which can include a right to possess such property….”

Supreme Court - The entries in jamabandi are not proof of title

 In Corporation of the City of Bangalore v. M. Papaiah and another (1989) 3 SCC 612 it was held that

 “it is firmly established that revenue records are not documents of title, and the question of interpretation of document not being a document of title is not a question of law.” 

In Guru Amarjit Singh v. Rattan Chand and others (1993) 4 SCC 349 The Supreme Court has held that 

“that the entries in jamabandi are not proof of title”. 

In State of Himachal Pradesh v. Keshav Ram and others (1996), 11 SCC 257 this Court held that 

“The entries in the revenue papers, by no stretch of imagination can form the basis for the declaration of title in favour of the plaintiff.”

Bombay High Court - A license does not create any title in favour of the licensee

 In the Matter of Suresh Malappa Shetty Vs. Special recovery officer, 2002 SCC Online BOM 1054; (2003) 3 Mah LJ 248

A license is treated to be in permissive possession only and possession is regarded to be with the licensor always. This usually happens in the case of joint development agreement / Collaboration agreement / License agreement and it is noteworthy that a license does not create any title in favour of the licensee

Complaints can be instituted against promoters in relation to both projects which have been registered with the authority or which are not registered with the authority

Simmi Sikka V/s M/S EMAAR MGF LAND LTD Complaint number RERA-GRG-7-2018

Haryana Real Estate Regulatory Authority Gurugram 

The judgement contains the following conclusions

• The RERA Act, nowhere mentions anywhere that it is applicable only for the registered projects.

• The RERA Act, provides certain categories of projects which are not required to be registered but these are within the ambit of the Act. These projects mentioned in section 3(2) have been taken out of the registration requirement but not out of the purview of other provisions of the Act.

• The provisions regarding registration and obligation during registration are applicable only for the registered projects.

• The obligations of the promoter’s post expiry of the validity of the registration provided in the Act are applicable to even the real estate projects exempted from the registration.

• The projects which were completed and handed over during the last 5 years are 

covered for the purpose of workmanship and structural defect liability.  A complaint may be filed by the allottee in such matter in case the possession of the real estate was within 5 years prior to the date of the complaint.

• All real estate projects are covered for land title defect liability

• A complaint pertaining to violation of the provisions of RERA Act, Haryana RERA Rules, and regulations thereunder, may be filed by any aggrieved person in respect of any real estate project as per the definition given in section 2(zn) of RERA Act.

Based on the above judgment, it may be concluded that registration of project and filing RERA complaint, both are separate activities. A RERA case can be filed even against the non-registered projects.