Subsequent purchasers may continue pending eviction proceedings, but impleadment does not establish entitlement to eviction.

The petitioner had been a tenant in the premises since 1 September 2004.

In 2013, the original landlord, respondent No. 1, commenced eviction proceedings alleging her personal and bona fide need, expiry of the agreed tenancy term, and arrears of rent.

While those proceedings were pending, she sold the premises to respondents Nos. 2–5, who applied to be impleaded and to continue the proceedings.

The Rent Tribunal allowed their application under Order XXII Rule 10 CPC read with Section 21 of the Rajasthan Rent Control Act, 2001.

The tenant challenged that order under Article 227, arguing that the purchasers could not pursue the original landlord’s personal-need ground.

Whether purchasers who acquired the premises during pending eviction proceedings could be impleaded and permitted to continue those proceedings under Order XXII Rule 10 CPC read with Section 21 of the Rajasthan Rent Control Act, 2001

Whether impleadment of the purchasers meant that the original landlord’s personal and bona fide necessity automatically survived in their favour

Order XXII Rule 10 CPC permits a proceeding to be continued, with the court’s leave, by or against a person upon whom an interest in its subject matter has been assigned, created, or devolved during its pendency.

Section 21 of the Rajasthan Rent Control Act, 2001 was invoked alongside that provision.

Impleadment under Order XXII Rule 10 concerns participation in and continuation of the proceeding; it does not establish the transferee’s substantive entitlement to eviction or dispense with proof of the grounds relied upon.

Under Article 227 of the Constitution, the High Court’s supervisory jurisdiction is not appellate or revisional and intervention is warranted for matters such as patent illegality, jurisdictional error, perversity, or grave procedural infirmity.

The registered sale deeds transferred an interest in the very premises that were the subject of the pending eviction proceedings.

The purchasers could therefore be brought on record so the Tribunal could effectively adjudicate the parties’ rights; their impleadment did not itself determine whether they were entitled to eviction.

The original landlord’s pleaded need to settle in Jodhpur and care for her mother was personal to her, and its survival—or the purchasers’ ability to establish an independent claim—was left for the Tribunal to decide on the pleadings and evidence.

The Tribunal was also to consider the other pleaded grounds, including expiry or termination of the tenancy and arrears, without treating impleadment as proof of those grounds.

As the Rent Tribunal’s order contained no patent illegality or jurisdictional error, Article 227 did not justify interference.

The writ petition was dismissed.

The Rent Tribunal was directed to decide the eviction proceedings on the pleadings and evidence, independently and in accordance with law, uninfluenced by the Court’s observations on the merits.