Prior Slum Act permission is unnecessary for eviction proceedings under Section 14(1)(e).

The tenants challenged the Rent Controller’s order dismissing their application for leave to defend and directing eviction from premises comprising portions of the ground, first and second floors at property No. 9333, Katra Ganga Bishan, Delhi.

They argued that the premises were in a notified slum area and that prior permission was required; that the proposed project plan wrongly included Khasra No. 502; and that the landlord’s financial capacity to undertake the proposed development had not been addressed.

The Rent Controller rejected the slum-permission objection and found that the lack of project-plan approval did not raise a triable issue, noting the proposed building plan, estimate, timeline and project report.

The tenants sought revision under Section 25-B(8) of the Delhi Rent Control Act, 1958 (“DRC Act”).

1. Whether the Rent Controller erred in rejecting the tenants’ objection that eviction proceedings under Section 14(1)(e) of the DRC Act required prior permission under the Slum Areas (Improvement and Clearance) Act, 1956 (“Slum Act”)

2. Whether the Rent Controller’s treatment of the project-plan objection disclosed a ground for interference in revision

3. Whether the tenants could rely in revision on objections concerning Khasra No. 502 and the landlord’s financial capacity when those grounds had not been raised before the Rent Controller

Section 25-B(8) of the DRC Act confers supervisory and revisional, not appellate, jurisdiction; the High Court does not reappreciate evidence or substitute its view for that of the Rent Controller, but may intervene for jurisdictional error, manifest illegality, material irregularity, perversity, an unreasonable conclusion, or failure to adjudicate a material plea; *Abid-Ul-Islam v. Inder Sain Dua*, (2022) 6 SCC 30; *Sarla Ahuja v. United India Insurance Co. Ltd.*, (1998) 8 SCC 119; *Hindustan Petroleum Corporation Ltd. v. Dilbahar Singh*, (2014) 9 SCC 78.

Under *Shafait Ali v. Shiva Mal (Dead) by LRs*, (1987) 3 SCC 728, the special procedure in Chapter III-A of the DRC Act prevails over inconsistent Slum Act requirements; prior permission under Section 19(1)(a) of the Slum Act is not required before instituting an eviction petition under Section 14(1)(e) of the DRC Act.

The High Court found that the Rent Controller had expressly considered and rejected the Slum Act objection, consistently with *Shafait Ali*; the objection therefore disclosed no error warranting revision.

The Rent Controller had also addressed the lack of governmental approval for the project plan, reasoning that approval could be sought after possession was obtained, and had considered the supporting project documents. That assessment was not shown to be perverse or unlawful.

The objections concerning Khasra No. 502 and financial capacity had not been raised before the Rent Controller, so the High Court declined to examine them for the first time in its limited revisional jurisdiction.

It dismissed the revision petition and disposed of the pending applications.