Madras High Court
Civil Procedure and EvidenceProperty and Real Estate Law

A tenant who admitted the rental agreement cannot belatedly seek signature comparison during arguments.

S. Leela vs A. Micheal George

Madras High CourtJUDGMENT: September 24, 20262 MIN READSOURCE JUDGMENT
A tenant who admitted the rental agreement cannot belatedly seek signature comparison during arguments.. S. Leela vs A. Micheal George. Madras High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The landlord filed R.L.T.O.P. No. 2 of 2026 seeking eviction for arrears of rent and related reliefs.

Source reference: para. 2

The tenant later applied under Section 45 of the Indian Evidence Act and Section 37(c) of the Tamil Nadu Regulation of Rights and Responsibilities of Landlords and Tenants Act to have the signature on the rental agreement compared with her admitted signatures.

Source reference: para. 2

She alleged that the disputed agreement was fabricated.

Source reference: para. 2

The landlord relied on the tenant’s reply notice, in which she had admitted entering into an agreement before the Rent Authority.

Source reference: paras. 5–6

The Rent Controller dismissed the application, noting the tenant’s admission and that the request for comparison was made when the matter was posted for arguments.

Source reference: paras. 9–11

The tenant challenged that order under Article 227 of the Constitution.

Source reference: paras. 2, 9–11
02

Issues

1. Whether the Rent Controller’s refusal to refer the disputed rental agreement for expert signature comparison warranted interference under Article 227

Source reference: paras. 2, 9–10

2. Whether the tenant’s prior admission of the agreement and the timing of her application justified rejecting the request for expert comparison

Source reference: paras. 5–6, 9–11
03

Law Applied

The tenant invoked Section 45 of the Indian Evidence Act, concerning expert opinion, and Section 37(c) of the Tamil Nadu Regulation of Rights and Responsibilities of Landlords and Tenants Act; the judgment does not set out or interpret the text of either provision.

Source reference: para. 2

The Court treated the Rent Controller proceedings as summary in nature and considered the tenant’s prior admission of the agreement and the belated timing of the comparison request relevant to whether the order warranted interference.

Source reference: paras. 7, 11

No precedent was cited.

Source reference: para. 11
04

Reasoning

The Court found that the tenant’s reply notice admitted the agreement between the parties and that her principal objection at that stage concerned liability for arrears, not execution of the agreement.

Source reference: para. 9

In light of that admission, the Court considered her later request to compare signatures—made when the case was posted for arguments—to be belated.

Source reference: para. 10

Given the summary nature of the proceedings, it found no error or illegality in the Rent Controller’s refusal to allow the comparison.

Source reference: para. 11
05

Holding

The Court held that the revision petition lacked merit and dismissed it, finding no basis to interfere with the Rent Controller’s order.

There was no order as to costs, and the connected miscellaneous petitions were closed.

Source reference: para. 12
06

Acts & Sections Cited

2 provisions across 2 statutes referred to in this judgment. Linked provisions open on LawLens.

Indian Evidence Act, 18721

Section 45

Tamil Nadu Regulation of Rights and Responsibilities of Landlords and Tenants Act, 20171

Section 37
Madras High Court

Original Court PDF

S. LeelavsA. Micheal George

Madras High Court · September 24, 2026

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