Section 25B(8) revision does not permit reappreciation of title evidence absent perversity or legal error.

The respondent sought eviction under Section 14(1)(e) of the Delhi Rent Control Act, 1958, claiming ownership of the premises under a registered sale deed executed by Smt. Sunita Rani.

The petitioners, who admittedly occupied the premises as tenants, disputed the respondent’s title. They asserted that the property had devolved from its original owner, Smt. Chameli Devi, to her daughter, Smt. Raj Dulari, and that Sunita Rani had no title to convey.

The respondent relied on Chameli Devi’s registered Will, under which the property was to pass to Sunita Rani after Raj Dulari’s death, as well as the sale deed, rent receipts and notices of attornment.

The Rent Controller rejected the tenants’ application for leave to defend; the tenants challenged that order in revision under Section 25B(8).

1. Whether the Rent Controller’s rejection of leave to defend disclosed an error warranting interference under the High Court’s limited revisional jurisdiction under Section 25B(8)

2. Whether the tenants’ challenge to Sunita Rani’s derivative title under the Will raised a triable issue requiring leave to defend, or otherwise undermined the respondent’s status as landlord for the purposes of the DRC Act

Section 25B(8) of the DRC Act confers supervisory and revisional, not appellate, jurisdiction: the High Court may examine the legality and propriety of the decision-making process but ordinarily cannot reappreciate the evidence or substitute its view for that of the Rent Controller; interference is warranted for such defects as jurisdictional error, manifest illegality, material irregularity, perversity or an error apparent on the record

In proceedings under Section 14(1)(e), the landlord need not establish absolute title as in a civil title suit; the relevant inquiry is whether the claimant is the owner/landlord vis-à-vis the tenant for the purposes of the Act

The Court also referred to *Pankaj Pahwa v. Prem Wati* and *Sanjeev Hiranandani v. Sunny Grover* on the limited scope of revision

and considered the petitioners’ reliance on *N.P. Saseendran v. N.P. Ponnamma*, *Inderjeet Kaur v. Nirpal Singh* and *Bismillah Be v. Majeed Shah*

The High Court found that the Rent Controller had considered the competing accounts of devolution, the Will, the sale deed and the evidence of the landlord–tenant relationship, including rent receipts and the attornment letter

The Controller had interpreted the Will as making Sunita Rani’s interest effective after Raj Dulari’s death; the High Court held that the tenants’ alternative interpretation did not, by itself, justify revisional reappraisal

The tenants claimed no proprietary interest themselves, and no heir or successor of Raj Dulari was shown to have challenged the Will or asserted competing title. In that context, the tenants had not established a defect in the Controller’s decision-making process sufficient to warrant interference

The documentary material was sufficient to support the respondent’s status as landlord for the DRC proceedings, without determining absolute title against all possible claimants

It dismissed the revision petition and the pending applications.