One of my work collegues had this problem. They owned a business and got a web designer to design the
website hosting (he also set up the hosting and domain names). After my collegue decided to dispense with his services, as he was not managing the
website hosting properly and had not even completed it he refused to transfer the domain name over. The designer in question had registered the domain name to himself personally and not his client.
In the end they had to register a new domain!