A tenant is estopped from challenging the landlord’s title or sale deed after admitting the landlord-tenant relationship.

The Petitioner, a tenant, challenged the order dated 20 September 2025 passed by the learned SCJ-cum-Rent Controller, District Central, Tis Hazari Courts, Delhi, in RC ARC No. 511/2024, concerning premises bearing Municipal No. 4804, First Floor (Right Side), with terrace/roof rights, Phatak Namak, Delhi.

The Respondents claimed ownership under a registered Sale Deed dated 16 May 2019 executed by Afroz Begum, the erstwhile landlord.

The Petitioner did not dispute execution of the Sale Deed but contended that it was void ab initio because Afroz Begum was only a co-owner and lacked authority to sell the entire property.

He further alleged that the Respondents had filed an incorrect site plan by failing to depict two rooms constructed on the terrace floor.

The Rent Controller rejected these objections, and the Petitioner invoked the revisional jurisdiction of the High Court under Section 25B(8) of the Delhi Rent Control Act, 1958.

Whether the Petitioner, having admitted the landlord-tenant relationship and execution of the registered Sale Deed, could challenge the Respondents’ title or the validity of the Sale Deed on the ground that the vendor was only a co-owner?

Whether the alleged discrepancy in the site plan, including the non-disclosure of two terrace rooms, constituted a triable issue warranting interference with the Rent Controller’s order?

Whether the Impugned Order disclosed a jurisdictional error, patent illegality, material irregularity, perversity, or an error apparent on the face of the record warranting interference under the proviso to Section 25B(8) of the DRC Act?

The Court applied the proviso to Section 25B(8) of the Delhi Rent Control Act, 1958, under which the High Court exercises supervisory and revisional, rather than appellate, jurisdiction over the Rent Controller’s order.

Relying on 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, the Court held that it cannot reappreciate evidence or substitute its own view merely because another view is possible; interference is confined to jurisdictional error, manifest illegality, material irregularity, perversity, absence of adjudication, or an error apparent on the face of the record.

The Court also applied the settled principle of landlord-tenant estoppel, holding that a tenant who admits the landlord-tenant relationship cannot ordinarily dispute the landlord’s title or the validity of a transfer by the admitted landlord.

A site-plan objection does not constitute a triable issue where the identity of the tenanted premises is otherwise clear and the relevant plan is admitted.

The High Court found that both objections had been expressly considered by the Rent Controller.

Regarding title, the Petitioner admitted the execution of the registered Sale Deed and the earlier landlord-tenant relationship with Afroz Begum.

Applying landlord-tenant estoppel, the Court held that the Petitioner could not challenge the Respondents’ title or the validity of the Sale Deed in the eviction proceedings merely by alleging that the vendor was a co-owner.

Regarding the site plan, the Rent Controller had recorded that the Respondents admitted the plan relied upon by the Petitioner to be correct.

Since the premises were specifically identifiable by their municipal number, floor, side, and terrace/roof rights, the alleged omission of two terrace rooms did not create uncertainty regarding the subject premises or raise a triable issue.

As the Rent Controller had considered and adjudicated both objections, and no jurisdictional error, perversity, patent illegality, or material irregularity was demonstrated, the restricted revisional jurisdiction under Section 25B(8) was not attracted.

It held that the Petitioner was estopped from disputing the Respondents’ title or the Sale Deed after admitting the landlord-tenant relationship and execution of the registered conveyance.

It further held that the site-plan objection did not constitute a triable issue because the identity of the tenanted premises was clear and the relevant plan stood admitted.

Finding no ground for revisional interference, the Court dismissed RC.REV. 45/2026 and disposed of all pending applications.

The next date of hearing, 15 September 2026, was cancelled.