Delhi HC Dismisses Tenant’s Eviction Challenge After Aadhaar-Based Claim That Rent Receipts Were Fabricated Came Too Late

The petitioner challenged the Additional Rent Controller’s eviction order dated 29 January 2026 under Section 25-B(8) of the Delhi Rent Control Act, 1958.

In revision, she disputed the landlord–tenant relationship and relied on rent receipts alleged to be fabricated, together with her Aadhaar card, said to show she was eight years old when the receipts were issued.

Counsel acknowledged that neither this factual plea nor the Aadhaar card had been placed before the ARC.

The petitioner also sought permission to place documents on the High Court record.

Section 25-B(8) of the Delhi Rent Control Act, 1958 confers limited revisional and supervisory jurisdiction on the High Court; it is not an appellate jurisdiction permitting reappreciation of the entire matter or substitution of the High Court’s view for that of the ARC.

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 stated that interference is confined to scrutiny of the legality and propriety of the decision-making process.

A new factual plea, unsupported by pleadings or evidence before the court of first instance, cannot ordinarily be introduced at the revisional stage; the Court relied on Gopal Krishna Sawhney v. Vinod Kumar, 2018 SCC OnLine Del 8064, including its discussion of National Textile Corporation Ltd. v. Naresh Kumar Badrikumar Jagad, (2011) 12 SCC 695, and J. Jermons v. Aliammal, (1999) 7 SCC 382.

The petitioner’s sole challenge depended on the rent receipts and Aadhaar card to dispute the landlord–tenant relationship, but the relevant plea and document had not been presented to the ARC.

Determining that challenge would require the High Court to consider a new factual case and undertake factual inquiry in the first instance, which was outside the restricted revisional role under Section 25-B(8).

As no other ground of illegality, material irregularity, or impropriety was urged, the Court found no basis to interfere.

The revision petition was dismissed, and the pending applications were disposed of; the hearing date of 21 January 2027 was cancelled.