Denial of a landlord-tenant relationship does not, by itself, oust Small Causes Court jurisdiction.

The petitioners challenged eviction orders dated 11 October 2019 in S.C. Nos. 15176, 15177 and 15178 of 2017, contending that no landlord–tenant relationship existed, that they had constructed on and occupied the property independently before the Trust was constituted, and that the Small Causes Court lacked jurisdiction.

They also disputed the trustee’s authority to sue.

The Trust relied, among other material, on the petitioners’ pleadings in O.S. No. 5728 of 2014 and the registered trust deed, which the Trust said supported its account of the parties’ relationship and the trustee’s authority.

The Small Causes Court found the relationship established and ordered eviction; the petitioners challenged those orders in revision.

Whether the petitioners’ denial of a landlord–tenant relationship deprived the Small Causes Court of jurisdiction to hear the ejectment suits.

Whether the Small Causes Court’s findings and eviction orders disclosed a jurisdictional error or other ground warranting interference in revision.

Whether the Managing Trustee was authorized to institute proceedings for recovery or protection of the Trust property.

The petitions were brought under Section 18 of the Karnataka Small Cause Courts Act, 1964, and the petitioners’ jurisdictional objection relied on Section 8 of that Act.

The Court described revisional review by reference to Section 115 of the Code of Civil Procedure, 1908: revision is supervisory, not appellate, and interference is warranted where the subordinate court exercised jurisdiction not vested in it, failed to exercise jurisdiction vested in it, or acted illegally or with material irregularity; a finding may also warrant interference if perverse or based on no evidence.

A denial of the landlord–tenant relationship does not, by itself, oust jurisdiction where the court has considered the pleadings and evidence and made a finding on that relationship.

The Court also treated the registered trust deed’s authorization of the Managing Trustee to institute proceedings as sufficient absent contrary material.

The High Court held that the Small Causes Court had considered the material and recorded a finding that the relationship necessary to maintain the ejectment proceedings was established; the petitioners did not show that the finding was perverse, unsupported by evidence, or jurisdictionally erroneous.

The petitioners’ earlier pleadings and the circumstances concerning collections from occupants were relevant to that finding, while the characterization of those payments as rent or donations was not, by itself, determinative in revision.

Their independent-possession and construction arguments would have required a properly pleaded and established factual basis, and revision was not the forum for a fresh factual inquiry.

The trust deed authorized the Managing Trustee to institute proceedings, and the petitioners identified no contrary provision or material.

It dismissed all three Civil Revision Petitions, affirmed the eviction orders dated 11 October 2019 in S.C. Nos. 15176, 15177 and 15178 of 2017, and disposed of any pending applications.