Core Legal Answer & Context: The Transfer of Property Act, 1882, generally mandates written and often registered instruments for the transfer of immovable property and certain other rights. For instance, a gift of immovable property (Section 123), a transfer of an actionable claim (Section 130), and a sale of immovable property of value Rs. 100 or upwards (Section 54) all require a written instrument, with registration often being compulsory. However, a surrender of lease, particularly if it is an implied surrender by operation of law or relates to a lease that itself did not require a registered instrument (e.g., a lease for a term not exceeding one year), can be effected orally or by conduct, without a formal written document.

Relevant Statutes and Sections: Transfer of Property Act, 1882, Sections 54, 107, 111(e), 123, 130.

Important Landmark Cases: Cases on implied surrender of lease support the possibility of oral or conduct-based surrender, distinguishing it from express surrender which may require writing.

Clear Conclusion: Surrender of lease may be made orally (especially by implication).