Subordinate authorities cannot nullify final orders of superior courts through restoration proceedings or jurisdictional overreach.

The appellant (tenant) was ordered to vacate a property in Saharanpur by the Rent Authority on 07.09.2022 under Section 21(2) of the U.P. Urban Premises Rent Control Ordinance, 2021

This order was affirmed by the District Judge, the High Court, and finally the Supreme Court, which dismissed the Special Leave Petition on 20.09.2024 and directed the tenant to vacate by 31.03.2025

Despite the dismissal of subsequent Review and Miscellaneous Applications by the Supreme Court, the tenant filed a restoration application before the Rent Authority (Additional District Magistrate) seeking to recall the original 2022 order

The Rent Authority allowed the restoration on 15.05.2025, citing a report (prepared by the same officer in their capacity as ADM) alleging the landlord’s title deeds were forged

The High Court set aside this restoration order, leading to the present appeal

1. Whether a Rent Authority possesses the jurisdiction to entertain a restoration or recall application after the underlying eviction order has been affirmed by the Supreme Court

2. Whether the Rent Authority can adjudicate questions of title or ownership under the U.P. Urban Premises Rent Control Act, 2021

3. Whether the conduct of a subordinate authority in disregarding the finality of superior court orders constitutes a breach of judicial discipline

The court applied Section 21(2) and Section 38 of the U.P. Urban Premises Rent Control Act, 2021, the latter of which expressly limits the Rent Authority’s jurisdiction to tenancy agreements and excludes questions of title or ownership

The court relied on the doctrine of judicial discipline as established in Union of India v. Kamlakshi Finance Corpn. Ltd., which mandates that subordinate authorities must follow superior court orders unreservedly

It further referenced Baradakanta Misra v. Bhimsen Dixit regarding the necessity of following settled law to avoid subverting the Rule of Law

M.A. Murthy v. State of Karnataka on the importance of binding precedents for legal certainty

The Court observed that the landlord-tenant relationship had been conclusively established through multiple tiers of judicial review, culminating in a binding direction from the Supreme Court to vacate the premises

It held that the Rent Authority’s attempt to recall this order was a nullity as it sought to compromise a finding already confirmed by the highest court

The Court critiqued the officer for conflating two roles; acting as ADM, the officer investigated title/forgery, and then used those findings—which are exclusively within the domain of Civil Courts—to pass orders as the Rent Authority

The Court emphasized that Section 38 of the Act strictly circumscribes the Authority’s power, making the restoration order an act without jurisdiction

Such "gross abuse of process" by the tenant and "overreaching" by the Authority was deemed a violation of judicial comity and the principle of finality

The order of the Rent Authority dated 15.05.2025 was declared void as a nullity for want of jurisdiction

The Court imposed a cost of ₹5 Lakhs on the appellant for the gross abuse of the legal process

Regarding the show-cause notice issued to the Rent Authority, the Court accepted the officer's unconditional apology but cautioned that Trial Courts must remain cognizant of the specific statutory limits of their jurisdiction