Your car moved to another dealer. Would you know?

MoRTH’s proposed Form 29CA could record the movement of a used car between authorised dealers. For the seller, it would make an otherwise invisible part of the journey visible.

You sell your car to an authorised dealer. The handover is recorded through Form 29C, and the portal generates an acknowledgement. The dealer becomes responsible for the car while it is in the dealer’s possession.

A few weeks later, the dealer passes the car to another authorised dealer, perhaps in another city where there is greater demand for that model. Your name may still appear on the RC because the final ownership transfer has not happened.

Would you know that the car had moved?

Under the current rules, there is no equivalent electronic record for this second handover. Form 29C records the movement from the seller to the first authorised dealer. It does not record a later movement between authorised dealers.

The Ministry of Road Transport and Highways is now proposing to fill that gap.

In July, MoRTH published draft amendments to the Central Motor Vehicles Rules. The draft introduces Form 29CA, an electronic intimation for the delivery of a car from one authorised dealer to another.

These are proposed rules, not law yet. But they recognise something the government record currently misses: a used car can move through more than one dealer before it reaches its final buyer.

What does Form 29C record today?

India introduced its deemed ownership framework through G.S.R. 901(E) in December 2022.

When a registered owner delivers a car to an authorised dealer, the owner and dealer can submit Form 29C electronically. The portal then generates an acknowledgement. The authorised dealer becomes the deemed owner and assumes responsibility for the car while it remains in the dealer’s possession.

Form 29C was an important first step because it created a timestamped record of the seller-to-dealer handover.

But it records only the first leg:

Seller → Form 29C → Dealer A

The record does not follow the car if Dealer A later hands it to Dealer B.

Why do cars move between dealers?

A dealer does not always find the final buyer in the market where the car was sourced.

A car may have stronger demand in another city. A smaller dealer may pass a specialised model to a dealer who understands that category better. This is a normal part of the used-car trade. Inventory moves towards demand.

The problem is not that the car moves. The problem is that the public record may not move with it.

If a challan, accident or police query arises later, the dealer chain may have to be reconstructed from private documents. The seller cannot simply open the government portal and see who had the car on that date.

That information should already exist.

What would Form 29CA change?

The proposed Form 29CA would create an electronic record when one authorised dealer delivers the car to another. The portal would generate an acknowledgement automatically.

The proposed journey would look like this:

Seller → Form 29C → Dealer A → Form 29CA → Dealer B → Form 30 → Buyer

If the car moves once more between authorised dealers, another Form 29CA would record that handover.

The form would identify the dealer transferring the car and the dealer receiving it. Vehicle details would be fetched from VAHAN after the registration number is entered, reducing the need to type the same information again.

The proposed changes also extend the deemed ownership framework to these dealer-to-dealer transfers. Dealer A would remain responsible while the car was with Dealer A. After the car was delivered to Dealer B and Form 29CA was submitted, responsibility would move to Dealer B.

The RC may continue to show the registered owner’s name during this intermediate period. But the system would know which authorised dealer had possession of the car.

The draft also says that the registered owner should be informed electronically when the original authorised dealer transfers the car onward.

Why are there limits on dealer transfers?

The draft permits no more than two dealer-to-dealer transfers before ownership must be transferred through Form 30.

A seller could hand the car to Dealer A. Dealer A could transfer it to Dealer B, and Dealer B could transfer it to Dealer C. Dealer C could not pass it to another dealer without completing an ownership transfer through Form 30.

A return counts as a transfer too. If Dealer A sends the car to Dealer B and Dealer B returns it to Dealer A, both permitted transfers have been used.

My reading is that this limit tries to recognise genuine dealer movement without allowing a car to circulate indefinitely in an interim state. That is the right principle. The government can review whether two is the right number after it sees how cars move under the system.

What happens after six months?

The draft creates an overall six-month limit from the date on which the registered owner submits Form 29C.

If ownership has not been transferred to a buyer through Form 30 within that period, registration would automatically move into the name of the last authorised dealer holding the car. That dealer would then appear in the ownership serial on the portal.

This gives deemed ownership a finish line.

Six months gives a dealer time to inspect, repair and sell the car. But the car cannot remain indefinitely between the seller’s RC and the eventual buyer. By the end of the period, it must either have a new registered owner or move into the name of the dealer holding it.

Where could the process still stop?

The proposed route would apply only to cars with valid registration, insurance and pollution-under-control certificates. Cars with pending challans, tax demands, unpaid user fees or active hypothecation would not be eligible. The draft also excludes cars involved in specified legal cases.

Those conditions are understandable, but the underlying records must be accurate. A repaid loan that still appears as active hypothecation, or an incorrectly pending challan, could prevent a legitimate transfer.

The portal therefore needs to tell the seller and dealer exactly why the process has stopped and how the underlying record can be corrected.

Form 29CA would also apply only to transfers between authorised dealers. It would not complete the final RC transfer, which would still require Form 30. Nor would it protect a private sale that takes place outside the authorised-dealer framework.

What should the seller be able to see?

The seller should not need to understand the architecture of VAHAN or remember several form numbers.

One page should show a simple timeline:

• The car was delivered to Dealer A.
• Dealer A acknowledged possession.
• The car was later delivered to Dealer B.
• Dealer B acknowledged possession.
• The final RC transfer was completed in the buyer’s name.

The draft provides for an electronic notification when the original dealer transfers the car onward. I would extend that principle to every permitted handover. The seller should be able to see which authorised dealer currently holds the car and when the six-month period ends.

Used cars already move between dealers. Form 29CA would give those movements a public timestamp, move responsibility with possession and allow the seller to follow the car towards its final owner.

A seller should not have to reconstruct a dealer chain after something goes wrong.

The chain should already be in the record.