Elucidate the following: In case of transfer of immovable properties, no right, title or interest can be transferred in the absence of Deed of Conveyance.

Usually a transaction of a sale of immovable property involves two documents, e.g., Agreement to sell and the Conveyance Deed i.e. sale deed. But with only a Sale Deed the transaction of sale can be completed. In Suraj Lamp & Industries Pvt Ltd. v. State of Haryana, the Supreme Court of India observed that it has become common practice to effect transfers of immovable property by way of either General Power of Attorney (GPA) sales or sale agreement, GPA or will transfers in order to evade, inter-alia, the payment of duties, taxes and other fees payable on transfer and registration (e.g., stamp duty or registration fees). The Apex Court held that such transactions are illegal and cannot be recognized as valid under law. Hon'ble Supreme Court further sought to distinguish these illegal transactions from genuine transactions entered into by parties in good faith. While referring to Sections 53A and 54 of the Transfer of Property Act, 1882 and its decisions in earlier cases, it further observed that a transfer of immovable property by way of sale can be effected only by a deed of conveyance. In the absence of a deed of conveyance, duly stamped and registered, no right, title or interest in an immovable property can be transferred.