Section 25B(8) revision is confined to jurisdictional errors and does not permit reappreciation of evidence.

The Petitioner-tenant challenged, under the proviso to Section 25B(8) of the Delhi Rent Control Act, 1958 (“DRC Act”), the order dated 19 February 2026 passed by the Additional Rent Controller (West), Delhi, in ARC No. 65/2020, concerning an eviction petition under Section 14(1)(e) of the DRC Act

The Petitioner admitted that he had been inducted as a tenant by Late Shri Mehnga Singh but disputed the Respondent’s status as landlord, principally challenging the genuineness of the Will through which the Respondent claimed succession to the premises

He further alleged that the Respondent lacked a bona fide requirement, possessed sufficient alternative accommodation, and had filed an incorrect site plan with the ulterior intention of selling the property

The learned ARC rejected these objections and held that no triable issue had been raised. The High Court examined the challenge within its limited revisional jurisdiction

Whether the Petitioner could dispute the landlord–tenant relationship and the Respondent’s title by challenging the genuineness of the Will relied upon by the Respondent

Whether the Respondent had established a bona fide requirement of the tenanted premises and lacked reasonably suitable alternative accommodation

Whether the allegation that the eviction petition was filed to facilitate sale of the property, and the objection regarding the incorrect site plan, raised a triable issue warranting interference

Whether the impugned order suffered from jurisdictional error, manifest illegality, material irregularity, perversity, or an error apparent on the face of the record warranting interference under Section 25B(8) of the DRC Act

The Court applied Section 25B(8) of the DRC Act, holding that the High Court’s jurisdiction is supervisory and revisional, not appellate; interference is permissible only for jurisdictional error, manifest illegality, material irregularity, perversity, absence of adjudication, or an error apparent on the face of the record, and not merely because another view is possible

Under Section 14(1)(e), a landlord need not establish absolute title as in a title suit but must show a title superior to that of the tenant

A tenant who entered the premises under a landlord is generally estopped from disputing the landlord’s title or succession; disputes concerning the genuineness of a Will are ordinarily matters between the legal heirs and cannot be used by the tenant as a defence to eviction

The Court relied on Sarla Ahuja v. United India Insurance Co. Ltd., (1998) 8 SCC 119; Hindustan Petroleum Corporation Ltd. v. Dilbahar Singh, (2014) 9 SCC 78; Abid-Ul-Islam v. Inder Sain Dua, (2022) 6 SCC 30; Bharat Bhushan v. Aarti Teckchandani, 2008 (153) DLT 247; Rajender Kumar Sharma v. Smt. Leela Wati, 155 (2008) DLT 383; and Dhanna Lal v. Kalawati Bai, (2002) 6 SCC 16, among others

A landlord is the best judge of the requirement and the tenant cannot dictate how the landlord should use the property; permissive occupation of premises belonging to the landlord’s father does not necessarily constitute reasonably suitable alternative accommodation

A bald challenge to a site plan, without producing an alternative site plan or supporting material, does not raise a triable issue

Section 19(2) provides a statutory remedy if the premises are transferred or otherwise dealt with contrary to the statutory restriction after eviction

The High Court found that the Petitioner’s induction as a tenant by Late Shri Mehnga Singh was undisputed. His challenge was confined to the genuineness of the Will under which the Respondent claimed succession. Applying the rule that a tenant cannot ordinarily challenge the title of the landlord or successor-in-interest in eviction proceedings, the Court held that the Respondent had demonstrated a title superior to that of the Petitioner and that any inter se succession dispute had to be resolved separately

On bona fide requirement, the ARC had considered the Respondent’s stated need for residence for himself and his family and had found that his existing occupation of premises belonging to his father was merely permissive and could not be treated as suitable alternative accommodation. The High Court held that this conclusion was consistent with the landlord’s right to determine his own reasonable residential requirements

The allegation of an intention to sell did not defeat the eviction claim because Section 19(2) furnished an appropriate remedy in the event of an impermissible transfer after eviction

Finally, the site-plan objection was unsupported by any alternative plan or documentary material and was therefore only a bald assertion

The ARC’s decision-making process disclosed no legally cognizable revisional error

Finding no jurisdictional error, illegality, material irregularity, perversity, or error apparent on the face of the record, the Court dismissed the revision petition under Section 25B(8) of the DRC Act

Pending applications, if any, were also disposed of