Limitation Act, 1963, Article 134, Civil Procedure Code, 1908, Section 47, 12, Order

21 - Rule 95 -- Limitation - Auction sale - Delivery of possession of property not asked

within the statutory period of one year - Remedy of regular suit for declaration of title
and recovery of possession is available subject to limitation.

https://nearlaw.com/PDF/MumbaiHC/2010/2010(1)-ALL-MR-756.html

PATTAM KHADER KHAN Vs.

PATTAM SARDAR KHAN & ANR.

Pottom Shader Khan v. Pottom Sardar Khan, 1996 (5) SCC 48: (1996 AIR SCW
3984) wherein it has been held that the issue of a sale certificate is not a sine qua non for
the maintenance of an application for delivery since the title of the Court auction
purchaser becomes complete on the confirmation of the sale under Order XXI, Rule 92,
CPC and by virtue of the thrust of Sec. 65, CPC, the property vests in the Court auction
purchaser from the date of sale and the sale certificate issued subsequently does not
create any title but is merely an evidence of title

M.S.M Haneefa v. United Finance

Corporation