Section 25-B(8) revision permits interference only for jurisdictional error, perversity, or manifest illegality.

The Petitioners challenged, under the proviso to Section 25-B(8) of the Delhi Rent Control Act, 1958 (“DRC Act”), the judgment dated 4 June 2026 of the learned Additional Rent Controller, Central District, Delhi, which rejected their application for leave to defend and passed an eviction order under Section 14(1)(e) of the DRC Act.

The Petitioners disputed the Respondent’s ownership and the existence of a landlord–tenant relationship, alleging that the rent receipts relied upon by the Respondent were forged and fabricated.

They also contended that the Respondent had more than 200 alternative shops and therefore lacked a bona fide requirement for the subject premises.

The learned ARC held that the Respondent had established a title superior to that of the tenants through the title documents and that the Petitioners’ assertion regarding alternative accommodation was vague and unsupported, particularly as the alleged shops were jointly owned and their exclusive availability and suitability had not been shown.

1. Whether the Petitioners had raised a triable issue regarding the Respondent’s ownership and the existence of a landlord–tenant relationship, including on the basis that the rent receipts were allegedly forged and that attornment had not taken place.

2. Whether the alleged availability of more than 200 other shops constituted reasonably suitable alternative accommodation so as to negate the Respondent’s bona fide requirement under Section 14(1)(e) of the DRC Act.

3. Whether the learned ARC’s rejection of leave to defend disclosed any jurisdictional error, perversity, manifest illegality, material irregularity, or error apparent on the face of the record warranting interference under the proviso to Section 25-B(8) of the DRC Act.

The Court applied Section 14(1)(e) and the proviso to Section 25-B(8) of the DRC Act.

Under Section 25-B(8), the High Court exercises limited supervisory and revisional jurisdiction and cannot reappreciate evidence as an appellate court or substitute its own view for a possible and reasonable view taken by the Rent Controller; interference is justified only for jurisdictional error, manifest illegality, material irregularity, perversity, or an error apparent on the face of the record.

Relying on *Sarla Ahuja v. United India Insurance Co. Ltd.*, *Hindustan Petroleum Corporation Ltd. v. Dilbahar Singh*, and *Abid-Ul-Islam v. Inder Sain Dua*, the Court reiterated the restricted scope of revision.

For ownership under the DRC Act, the landlord need not establish absolute or indefeasible title; it is sufficient to show a title or right superior to that of the tenant, as recognised in *Jiwan Lal v. Gurdial Kaur*, *Ramesh Chand v. Uganti Devi*, and *Smt. Shanti Sharma v. Smt. Ved Prabha*.

A tenant is generally estopped under Section 116 of the Indian Evidence Act, 1872, from denying the landlord’s title during the continuance of the tenancy.

No fresh attornment is necessary upon transfer or devolution of the landlord’s rights.

In relation to alternative accommodation, the accommodation must be available, reasonably suitable, and comparable in convenience and utility; although the landlord is ordinarily the best judge of his requirement, the choice cannot be fanciful, whimsical, or wholly unreasonable, as explained in *Shiv Sarup Gupta v. Dr. Mahesh Chand Gupta*, *Ragavendra Kumar v. Firm Prem Machinery*, and *Balwant Singh v. Sudarshan Kumar*.

Leave to defend is warranted only where the affidavit discloses facts which, if proved, would disentitle the landlord from obtaining eviction.

The Court held that the learned ARC had properly examined the chain of title, including the registered sale deed, gift deed, Will, and death certificate, and had also considered the Petitioners’ own admission that they were successors-in-interest of the original tenant.

Since the Respondent demonstrated a title superior to that of the Petitioners, absolute title adjudication was unnecessary in the eviction proceedings.

The absence of separate attornment did not undermine the landlord–tenant relationship because the landlord’s rights devolved upon the Respondent by operation of law after acquisition of the property.

The allegation of forged rent receipts was found to be bald and unsupported by any contrary rent receipts or contemporaneous material; the ARC had considered the explanation that the receipts were signed on behalf of the deceased tenant’s business or by his representative.

On alternative accommodation, the Petitioners failed to identify any particular shop that was exclusively owned or possessed by the Respondent, vacant, immediately available, and reasonably suitable for the pleaded requirement.

The mere existence of jointly owned shops could not establish suitable alternative accommodation, and accepting the Petitioners’ contention would impermissibly substitute their assessment for that of the landlord.

As the ARC had considered the relevant objections and adopted a legally permissible and reasonable view, the High Court found no basis for revisional interference.

It held that no triable issue arose concerning the Respondent’s ownership or the landlord–tenant relationship, and that the alleged alternative properties did not constitute reasonably suitable accommodation.

The learned ARC’s rejection of leave to defend and the eviction order were neither perverse nor affected by jurisdictional error, manifest illegality, material irregularity, or an error apparent on the face of the record.

The revision petition was accordingly dismissed, and all pending applications were disposed of.