Farmland Conversion "Applied For": Wait for the Order Before You Register

Quick Verdict (2026)

Hold off. Filing for conversion does not convert anything. Until the order is issued, the law still sees farmland. A seller whose file is only "applied for" can give you no change of land use, no right to build, and no safety net should the authority reject the request or let it lapse. Karnataka vests the power to change land use in Section 95 of the Karnataka Land Revenue Act 1964. Even after the 2025 relaxation, conversion is complete only at one of two moments: the planning authority issues its signed certificate, or the Deputy Commissioner issues an order once the conversion fee has been paid. So a pending file is not conversion, and neither is a thirty-day "deemed" approval with the fee outstanding. If you have to act now, sign a registered agreement to sell that depends on the order being issued. Hold the balance of the price until you have the order and the revenue record carries it. Register the sale deed after the order.

What an "Applied For" File Really Is

A seller who says the conversion is applied for can usually show only an acknowledgement number and a fee receipt. These leave the land as it was. In the application, a person asks a revenue or planning authority for leave to put one survey number to non-farm use. That authority may approve, approve with conditions, or refuse. It often refuses or holds the file for land in a green belt, in a lake or tank buffer, in a defence or airport zone, or on a road alignment, and also when the fee or papers are incomplete. The authority has to decide before the file has any legal effect on the land's classification.

Buying land and converting it are two events with separate risks. Sellers who blend them, with "the file is in, it is practically converted", ask you to bear the conversion risk while you pay a converted-land price. Treat the conversion as unfinished until the order is in your hands. Set the price and the terms of the deal on that footing.

Karnataka's 2025 Reform and Where It Misleads

Karnataka did speed things up in 2025. A confident seller will cite this, so know it precisely. The Karnataka Land Revenue (Amendment) Rules 2025 came into final force by notification on 23 December 2025, after a draft appeared on 17 September 2025. They set up two routes. If the land falls in an approved master plan zone and fits its zoning, the Deputy Commissioner is bypassed: the planning authority itself checks the particulars, takes the conversion fee and issues a digitally signed certificate. If the land lies outside a master plan zone, the file goes to the Deputy Commissioner as before, and an application left undecided for thirty days is treated as deemed provisionally approved. Note "provisionally". At that point the rules trigger an automatic demand for the fee, and the signed order follows only after payment. A plot on day thirty-one with the fee still unpaid is not converted. Two other 2025 changes are also relevant: conversion is no longer needed where up to two acres go to a new industry, and land used for renewable energy projects is exempt, on payment of the prescribed fee.

"Deemed" is the word that traps people. Nearness to a city, or thirty days on the calendar, does not make land deemed converted. The master-plan route and deemed approval apply to named land in named zones on stated conditions. They remedy administrative delay for a complete application that qualifies. They are not a device for a seller to use on a file that is incomplete, contested, or concerns land that never qualified. You cannot rely on "thirty days are nearly up, so count it as converted". Find out whether the order or certificate has been issued, and read what it says.

A deeming clause still does not produce a certificate automatically. Smt. Gali Ashwathamma v. State of Karnataka (2025:KHC:5365), decided on 6 February 2025, concerned the earlier four-month deeming clause in Section 95(5). The court said that once conversion is deemed, the Deputy Commissioner has only two jobs left, which are collecting the fee and issuing the certificate. The petitioner still waited roughly two and a half years and had to file a writ petition to get the certificate. That distance between paper approval and a certificate you can hold is what the phrase "as good as converted" asks you to pay for.

Registration Before Conversion: Is It Allowed?

Often it is, and that is what lulls buyers into a false sense of safety. A Sub-Registrar who receives a sale deed performs mostly a ministerial duty. He registers an instrument that is validly executed and stamped. Whether the land may lawfully be built on is not for him to decide. Karnataka has already dropped its old ban on non-agriculturists buying farmland: the Karnataka Land Reforms (Amendment) Act 2020 omitted Sections 79A, 79B and 79C, and reduced Section 80 from a blanket bar to a limit on certain lands. A resident Indian need not be a farmer to buy agricultural land there, and the deed can frequently be registered while the land is still agricultural.

That window could close. On 24 August 2026, the Karnataka Assembly passed the Registration (Karnataka Amendment) Bill, an earlier version having been withdrawn. Sub-registrars would have to turn away any sale or agreement to sell that lacks the State's prescribed documents, which may include a conversion order, a sanctioned plan and an e-khata. You are not bound by this until the change comes into force and the list is prescribed, so the position above stands for now. Even so, it shows where things are heading. Ask your sub-registrar's district office what rule applies today before you assume that unconverted land can still be registered.

Registering a sale and being able to use the land are not the same. A registered deed over unconverted land makes you the owner of farmland, and nothing more. Building-plan sanction, layout approval, an occupancy certificate, water and power connections, and in almost every case a bank loan for construction all stay out of reach. You would own farmland bought at a plot price, with no path to a plan, a layout approval or, normally, a construction loan.

There is another cost at the registration counter, and it is less visible. Say the price is that of a converted site, but the deed describes agricultural land to attract lower stamp duty. That is undervaluation. The registering authority can invoke the state's undervaluation provision: Section 45-A of the Karnataka Stamp Act 1957 in Karnataka, or Section 47-A of the Indian Stamp Act as amended in Tamil Nadu, Telangana and Andhra Pradesh. It can send the deed for a determination of market value and later collect the unpaid duty together with a penalty. Registering before conversion to save duty saves nothing. It postpones the bill, with interest.

The Encumbrance Certificate Will Never Show a Conversion Order

A clean paper misleads many buyers at this point. Under the Registration Act 1908, an encumbrance certificate searches registered instruments against a survey number for a period that you choose. Conversion orders come from a revenue or planning authority and are not registered instruments. So the certificate cannot show one, whether it exists or not. If a plot of farmland has a 30-year certificate with no entries, the only conclusion is that no sale or mortgage was registered against it. Whether a house may be built there lawfully remains unanswered.

Two other places hold conversion status. One is the order or certificate, identified by file number and date. The other is the revenue record, namely the RTC or pahani with its nature-of-land column, which mutation updates to reflect the new use. An order that was granted but never entered in the RTC means a half-done conversion, and this is a warning sign and not comfort. The record that the next buyer, bank or planning office reads would still say agricultural. To settle the question, compare the order with the current RTC nature column and the sanctioned zoning. The encumbrance certificate that everyone asks for first cannot do it.

Each State Has Its Own Instrument

Land is a state subject, so the conversion document and the law behind it change from state to state. When a seller says casually "it is converted", tie that statement to the correct document for the state concerned.

For Karnataka, the document is the DC's conversion order or, since the 2025 rules, the planning authority's conversion certificate, both under Section 95 of the Karnataka Land Revenue Act 1964. Telangana is governed by the Telangana Agricultural Land (Conversion for Non-Agricultural Purposes) Act 2006 (Act 3 of 2006), and the competent authority's NALA permission is mandatory before farmland goes to residential, commercial or industrial use. In Maharashtra the document is the non-agricultural (NA) order, or Sanad. A reform deserves notice: the 2025 amendment of the Maharashtra Land Revenue Code removed the separate NA permission where the land is already shown as non-agricultural in a sanctioned Development or Regional Plan, and brought in a one-time premium instead of the yearly NA assessment. In those plan areas, what a seller must show may be the plan entry and not a new NA order. The aim is not to memorise each state. Insist on seeing the particular conversion document that your own state's law recognises, and verify it against the record.

Registering First, Then Facing a Refusal

Run the pending application forward. You register and pay the full price. Then the authority refuses conversion, or the file lapses because an objection stays unresolved, or the claim of deemed approval turns out not to cover your plot. You are now registered owner of farmland for which you paid a site price. Neither a building plan nor a construction loan is available. Any structure is unauthorised and can be demolished. Putting the land to non-agricultural use without the order invites a penalty as well. A 2025 amendment in Karnataka rewrote the punishment for selling farmland for non-agricultural purposes without conversion. The old regime of imprisonment and a small fine gave way to a monetary penalty of about Rs. 1 lakh. This misuse penalty may also be noted against the land in the revenue record, which means a later owner can inherit it and the person who broke the rule does not alone bear it. What remains is a claim against the seller under the sale agreement, and that is worth far less than the order you should have demanded first.

The sums involved make this concrete. The gap between the price of farmland and the price of a converted site is frequently the whole margin in the deal. That gap is the conversion risk, which a seller with a file still "applied for" is trying to pass to you.

The One Document to Demand, and the Right Order of Steps

Ask for a single thing and refuse any substitute. It is the signed conversion order or certificate, with its file number and date, that names your survey number, your extent and the purpose applied for. A consultant's assurance, an acknowledgement, a fee receipt or a screenshot of the application status page is not that document. Then carry out three checks yourself. First, compare the survey number, extent and purpose on the order with the sale deed and the mother deed. Second, make sure the RTC or pahani nature-of-land column has truly been updated, and that more than an order on paper exists. Third, see that the zoning of the plot under the master plan or development plan permits the use, since an order that contradicts zoning leads to a dispute later.

If the order is not yet out and you still want to tie up the deal, leave the sale deed unregistered. Sign a registered agreement to sell instead, with completion conditional on the order being issued within a fixed time. Keep a real part of the price with the buyer until then, and state clearly that the money is refunded if conversion is refused or the time limit passes. In this way the conversion risk stays with the seller, who controls the application, until the order exists.

Do This Before Paying

Get the current RTC or pahani read for the exact survey number, and look at the nature-of-land column yourself instead of trusting a screenshot from the seller. If the land is agricultural and the conversion is just "applied for", ask for the signed order or certificate with file number and date. Confirm on your own that it exists, that it fits your survey number and purpose, and that the revenue record reflects it. Parts of this are covered in our other pieces on land conversion, on the rules for non-farmers buying agricultural land in Karnataka, and on general checks for buying agricultural land. A Karnataka title and record review brings them together. Read two further pieces in full. One explains why a clean encumbrance certificate is not enough, as an EC cannot show conversion at all. The other, on how to read an encumbrance certificate, shows what it covers and does not. A third explains what property mutation does, since mutation is the step that brings a conversion order into the record.

LegiScore is a technology provider. Our title search takes the survey number and reads against it the nature-of-land column of the RTC or pahani, the mutation history and the registered documents. A farmland classification with no recorded conversion is flagged for the follow-up described here. It checks what the documents say, notes what is missing from the file (here, the conversion order), and puts the risk before the buyer to acknowledge before committing. That differs from a single read-through that stops at a clean encumbrance certificate. It is no substitute for a lawyer's opinion on whether a given conversion order is valid. Start a report before you register a sale of land with conversion still only applied for.

The company behind LegiScore, LawyerDesk Advocacy Pvt Ltd, provides technology that supports legal and title verification. It is not a law firm and does not give legal opinions. Reach us at info@legiscore.in.