Once an order was made under Order 21 Rule 92 confirming the sale - judgment debtor had no right or title in the property - issue of sale certificate is a ministerial act and not judicial.

Sagar Mahila Vidyalaya, Sagar v. Pandit Sadashiv Rao Harshe & Ors., 

AIR 1991 SC 1825

(1991) 3 SCC 588, held as under :-

"the sale of the property in question was perfectly valid and as soon as the sale was confirmed under Order 21 Rule 92 CPC, the judgment debtor had no right or title in the property. Once an order was made under Order 21 Rule 92 confirming the sale, the title of the auction purchaser related back to the date of sale as provided under Section 65 CPC. The title in the property thereafter vests in the auction purchaser and not in the judgment debtor. The issue of sale certificate under Order 21 Rule 94 CPC in favour of the auction purchaser though mandatory but the granting of certificate is a ministerial act and not judicial