Revisional Court cannot disregard material documentary evidence merely for lack of formal exhibition during trial.

The Petitioner-Bank filed a revision petition under Section 25B(8) of the Delhi Rent Control (DRC) Act, 1958, challenging a judgment dated 10.02.2026 passed by the ARC, which dismissed the Bank’s eviction petition.

The ARC had ruled that the Resolution dated 06.10.2018 (authorizing the Bank’s CEO to litigate) was not "exhibited" during evidence and, further, only authorized the continuation of pending proceedings, not the institution of new ones.

The Petitioner contended that the document was part of the record and was misinterpreted.

1. Whether the High Court, in its revisional jurisdiction, can interfere with a finding of the ARC regarding the interpretation of a material document.

2. Whether the ARC erred in law by refusing to consider a material document (the Resolution) solely because it was not formally exhibited, despite being part of the record.

3. Whether the ARC's hyper-technical interpretation of the Resolution—limiting authority to pending cases—constituted a material irregularity.

Section 25B(8) of the Delhi Rent Control Act, 1958, which grants the High Court revisional power to satisfy itself regarding the legality and propriety of an order passed by the Rent Controller.

The principles established in Sarla Ahuja v. United India Insurance Co. Ltd., Hindustan Petroleum Corporation Ltd. v. Dilbahar Singh, and Abid-Ul-Islam v. Inder Sain Dua, which clarify that revisional jurisdiction is supervisory, not appellate, and is limited to correcting jurisdictional errors, manifest illegalities, or "errors apparent on the face of the record".

The Court observed that while its jurisdiction is restrictive, interference is warranted when the lower court's decision is founded upon an erroneous premise of law or a material plea is left unconsidered.

The Court found the ARC’s reasoning "incongruous" because the ARC extracted the Resolution in Paragraph 19 of its judgment—acknowledging its existence on record—but then refused to consider it in Paragraph 20 on the technical ground that it wasn't formally "exhibited".

The ARC's interpretation was found fundamentally flawed as it focused narrowly on one phrase ("proceedings initiated by or against the Bank") while ignoring subsequent clauses that explicitly authorized the CEO to "sign, file, verify and present pleadings" and "petitions".

This failure to read the document as a whole constituted a material irregularity in the decision-making process.

The High Court set aside the Impugned Judgment dated 10.02.2026 and remanded the matter to the ARC for fresh consideration on merits.

The parties were directed to appear before the ARC on 07.08.2026.