Section 25B(8) Revision Does Not Permit Reappreciation of Evidence Absent Manifest Error.

The Respondent obtained an eviction order under Section 14(1)(e) of the Delhi Rent Control Act, 1958, after the learned Additional Rent Controller dismissed the Petitioners’ application for leave to defend concerning premises at Property No. 6072, Gali Ravidas, Nabi Karim, Paharganj, Delhi.

The Respondent relied on a pleaded chain of title originating in a registered sale deed dated 7 May 1948 and asserted a landlord–tenant relationship and bona fide residential need.

The Petitioners disputed ownership and the tenancy, alleged alternative accommodation, and challenged the eviction order in revision under Section 25-B(8).

1. Whether the learned ARC’s finding that no triable issue arose regarding the Respondent’s ownership and the landlord–tenant relationship warranted revisional interference

2. Whether the allegations of forgery and the discrepancy between property numbers 6070 and 6072 disclosed a ground for interference, when those objections had not been raised before the ARC

3. Whether the Petitioners’ assertions of suitable alternative accommodation raised a triable issue requiring leave to defend

4. Whether the impugned order disclosed an error warranting interference within the limited revisional jurisdiction under Section 25-B(8)

Section 25-B(8) of the Delhi Rent Control Act confers supervisory and revisional, not appellate, jurisdiction: the High Court does not reappreciate evidence or substitute its view for that of the ARC, and interferes where the decision-making process discloses a jurisdictional error, manifest illegality, material irregularity, perversity, or failure to adjudicate a material plea (Abid-Ul-Islam v. Inder Sain Dua; Sarla Ahuja v. United India Insurance Co. Ltd.; Hindustan Petroleum Corporation Ltd. v. Dilbahar Singh).

Under Section 14(1)(e), the landlord must establish bona fide need and lack of reasonably suitable alternative accommodation; suitability is assessed in context, and the landlord is ordinarily the best judge of the requirement (Shiv Sarup Gupta v. Mahesh Chand Gupta; Sudesh Kumar Soni v. Prabha Khanna).

A tenant relying on alternative accommodation must plead particulars and place material supporting its availability and suitability, though foolproof documentary proof is not required at the leave stage (Lalta Prasad Gupta v. Sita Ram).

A tenant cannot claim adverse possession against the landlord while in permissive possession (Brij Narayan Shukla v. Sudesh Kumar; Ramesh Kumar Banga v. Kailash Makkar).

The High Court found that the ARC considered the Respondent’s pleaded title and the Petitioners’ unsupported and unclear account of ownership through other persons; its conclusion on ownership and the landlord–tenant relationship was not shown to be perverse.

The forgery allegation had not been raised before the ARC and lacked supporting material, while the property-number discrepancy was likewise raised for the first time in revision and was not shown to create uncertainty or prejudice.

The Petitioners’ alternative-accommodation assertions were unsupported by particulars or material demonstrating availability and suitability; moreover, they had not disputed the pleaded bona fide need or the extent of the Respondent’s family.

The Court therefore found no failure to adjudicate a material plea or other defect justifying revisional intervention.

It dismissed the revision petition and disposed of the pending application(s).