Revisional jurisdiction under Section 25-B(8) cannot reappreciate evidence or examine unsupported subsequent facts.

The petitioners-tenants challenged the judgment dated 19 August 2025 of the CCJ-cum-ARC, Central District, Tis Hazari Courts, Delhi, in RC ARC 466/2022.

The learned ARC dismissed their application for leave to defend and passed an eviction order concerning Shop No. XIII-5122, Harphool Singh Building, Subzi Mandi, Clock Tower, Delhi, under Section 14(1)(e) of the Delhi Rent Control Act, 1958.

The respondent-landlord claimed bona fide requirement of the premises to establish an office for his daughter, a practising lawyer, citing its ground-floor location, proximity to Tis Hazari Courts, accessibility to clients, and visibility.

The petitioners contended that the daughter had subsequently left India and relinquished her Indian citizenship, and that an adjacent Shop No. 5123 was vacant and constituted reasonably suitable alternative accommodation.

The respondent disputed both contentions, maintaining that the alleged subsequent development was unsupported and that the adjacent shop was co-owned and occupied by his brother, Pradeep Sapra.

The High Court examined the challenge in revision under Section 25-B(8) of the Act.

Whether the landlord’s requirement of the subject premises for establishing an office for his daughter was bona fide, notwithstanding the petitioners’ assertion that she had subsequently left India and relinquished her Indian citizenship.

Whether Shop No. 5123, allegedly lying vacant adjacent to the subject premises, constituted reasonably suitable alternative accommodation available to the respondent-landlord.

Whether the findings of the learned ARC disclosed perversity, jurisdictional error, manifest illegality, material irregularity, or an error apparent on the face of the record warranting interference under Section 25-B(8) of the Delhi Rent Control Act.

The Court applied Section 25-B(8) of the Delhi Rent Control Act, 1958, under which the High Court exercises limited supervisory and revisional jurisdiction rather than appellate jurisdiction.

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 held that it may interfere only for jurisdictional error, material irregularity, manifest illegality, perversity, an error apparent on the face of the record, or failure to consider a material plea; it cannot reappreciate evidence or substitute its own view for that of the Rent Controller.

Under Section 14(1)(e), a landlord’s requirement for settling or supporting a dependent child in a profession may constitute bona fide requirement, as recognised in Labhu Lal v. Sandhya Gupta, Ravinder Singh v. Deepesh Khorana, and Sunder Singh Talwar v. Kamal Chand Dugar.

Alternative accommodation defeats an eviction claim only when it is reasonably suitable and available to the landlord in comparison with the tenanted premises, applying Shiv Sarup Gupta v. Dr. Mahesh Chand Gupta, AIR 1999 SC 2507.

The Court held that the ARC had properly considered the pleaded requirement of the respondent’s daughter for a legal office and had given rational reasons, including the premises’ proximity to Tis Hazari Courts, accessibility, ground-floor location, and visibility.

The petitioners’ assertion that the daughter had left India and surrendered her citizenship was raised only orally before the High Court, was neither pleaded nor supported by material on record, and could not be used to displace the ARC’s finding or trigger a fresh factual inquiry in revision.

Regarding alternative accommodation, the ARC had considered the photographs and electricity bills relating to Shop No. 5123.

A shuttered shop and zero electricity consumption did not establish the respondent’s exclusive possession.

Further, the electricity connection stood in the name of the respondent’s brother, supporting the respondent’s case that the premises was co-owned and occupied by the brother.

Since the petitioners essentially sought a different appreciation of the same evidence, their challenge fell outside the restricted scope of Section 25-B(8).

The ARC’s conclusion that the adjacent shop was not reasonably suitable accommodation available to the respondent was neither perverse nor legally infirm.

It held that the landlord’s requirement was bona fide and that Shop No. 5123 did not constitute reasonably suitable alternative accommodation.

Finding no perversity, jurisdictional error, material irregularity, manifest illegality, or error apparent on the face of the record, the Court dismissed the revision petition and disposed of all pending applications.