A specific challenge to rent-receipt signatures raises a triable issue warranting leave to defend.

The respondents sought eviction of the petitioner from Shop No. E16/607/B/3, Tank Road, Bapa Nagar, Karol Bagh, relying, inter alia, on rent receipts to establish the landlord–tenant relationship.

The petitioner sought leave to defend, specifically disputing the signatures on the receipts and alleging forgery.

The learned ARC rejected that defence, including on the ground that the petitioner had not produced specimen signatures from his bank records, and dismissed the leave application.

The petitioner challenged that order under Section 25B(8) of the Delhi Rent Control Act, 1958.

1. Whether the learned ARC erred in rejecting the petitioner’s specific challenge to the genuineness of the rent receipts when deciding whether to grant leave to defend

2. Whether that alleged error warranted interference in the High Court’s limited revisional jurisdiction under Section 25B(8) of the Delhi Rent Control Act

Section 25B(8) of the Delhi Rent Control Act, 1958 confers a limited supervisory and revisional jurisdiction on the High Court, not an appellate power to reappreciate evidence or substitute its view for that of the Rent Controller. Sarla Ahuja v. United India Insurance Co. Ltd., (1998) 8 SCC 119; Hindustan Petroleum Corporation Ltd. v. Dilbahar Singh, (2014) 9 SCC 78; and Abid-Ul-Islam v. Inder Sain Dua, (2022) 6 SCC 30, affirm that the High Court’s scrutiny is directed to the legality and propriety of the decision-making process. Interference may be warranted for a jurisdictional error, manifest illegality, material irregularity, perversity, an erroneous premise of law, or failure to consider a material plea.

At the leave-to-defend stage, the question is whether the disclosed defence raises a triable issue, not whether the tenant has conclusively proved it.

The petitioner specifically disputed the signatures on the rent receipts relied on to establish the landlord–tenant relationship. The receipts displayed materially varying markings, and signatures on the leave application, its supporting affidavit and the revision petition were also available on the record.

The High Court did not determine whether the receipts were forged or independently compare the signatures. It found instead that the ARC had rejected a material defence by requiring bank specimen signatures without considering whether the material already on record disclosed a triable issue.

This was an error in the decision-making process, rather than a mere disagreement over evidentiary appreciation, and therefore fell within the limited revisional jurisdiction.

The respondents’ other submissions, including their contention concerning ownership, did not cure the failure to address the challenge to the documents relied on to establish the foundational landlord–tenant relationship.

It set aside the impugned order, allowed the application for leave to defend, and remanded the eviction petition to the ARC for adjudication after affording the parties an opportunity to present their pleadings and evidence.

The ARC was directed to decide the matter uninfluenced by the High Court’s observations; the matter was listed before the ARC on 14 October 2026.