In 2012, in the case of Suraj Lamp & Industries (P) Ltd (2) v Den, while dealing with the validity of sales of real estate made by proxy, the Supreme Court of India ruled as follows: in many cases, the property still does not become a legal buyer until he or she has paid the full purchase price, which could take years. Nevertheless, the buyer can take possession of the property while paying. A contract of sale is a promise in the future that the property will be transferred to the rightful owner, while the deed of sale is the actual transfer of ownership to the buyer. Of course, a sales contract is often used for seller financing when the seller lends money to the buyer to pay for the house. This type of transaction can occur if the buyer cannot qualify for a traditional mortgage. Even if the signing of the sales contract does not mean that the sale is over, it is a decisive step in this direction. For this reason, buyers need to know precisely the conditions set out in the agreement. For example, a buyer and seller can use this method if the buyer does not have the money to pay in full. If the seller doesn`t need all the money or doesn`t care about letting the buyer reside on the land while they pay for it, they could come up with a purchase agreement to clarify the agreement and protect both parties. “A contract for the sale of immovable property is a contract that is carried out on the terms agreed between the parties” – Section 54. .