The Supreme Court has come down heavily on a tenant for repeatedly attempting to delay eviction proceedings despite multiple adverse orders, terming the conduct a “gross abuse of process of law.”
The bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh not only dismissed the tenant’s plea but also imposed costs of Rs. 5 lakh and issued a show-cause notice to a Rent Authority officer for acting beyond jurisdiction.
The case arose from a long-standing landlord-tenant dispute concerning a property in Saharanpur, Uttar Pradesh. The landlord had initiated eviction proceedings under the U.P. Urban Premises Rent Control Ordinance, 2021, citing non-payment of rent.
The Rent Authority, Appellate Authority, and subsequently the Allahabad High Court all ruled in favor of the landlord, confirming the existence of a landlord-tenant relationship and directing eviction. The Supreme Court had earlier dismissed the tenant’s Special Leave Petition (SLP) and granted time until March 31, 2025, to vacate the premises.
Despite this, the tenant continued filing review petitions and miscellaneous applications—all of which were dismissed.
In a surprising turn, the tenant filed a restoration application before the Rent Authority challenging the original eviction order. The authority allowed the application, effectively reopening a matter that had already attained finality up to the Supreme Court level.
The High Court later set aside this restoration order, prompting the tenant to approach the Supreme Court again.
The Supreme Court refused to entertain the fresh plea, observing that the tenant’s actions were a clear attempt to overreach and undermine binding judicial orders. The Court emphasized that once a matter has been conclusively decided, subordinate authorities cannot reopen or nullify such findings.
It noted that the Rent Authority’s action in entertaining the restoration application was legally untenable, especially when the issue had already been settled by higher courts.
A key issue examined by the Court was the conduct of the Additional District Magistrate (ADM), who acted as the Rent Authority. The Court found that the ADM had relied on findings from a separate administrative inquiry regarding alleged irregularities in the landlord’s title to justify reopening the eviction proceedings.
The Court clarified that the Rent Authority’s jurisdiction is limited to examining the landlord-tenant relationship. Questions of title or ownership fall exclusively within the domain of civil courts.
By venturing into title disputes and effectively nullifying prior judicial findings, the authority acted beyond its statutory powers. The Court declared the restoration order “void” due to lack of jurisdiction.
The Supreme Court also highlighted the importance of judicial discipline and adherence to the hierarchy of courts. It reiterated that subordinate authorities must follow decisions of higher courts without deviation.
The Court warned that such actions undermine the rule of law and create uncertainty in legal administration. It referred to past precedents emphasizing that failure to follow binding judgments can amount to contempt.
Given the seriousness of the lapse, the Court had issued a show-cause notice to the concerned officer. However, after the officer tendered an unconditional apology, the Court accepted it and clarified that the proceedings would not adversely affect the officer’s career.
The tenant was directed to pay ₹5 lakh as costs to the Supreme Court Middle Income Group Legal Aid Society. The appeal was dismissed.
The Court reiterated that jurisdictional boundaries must be strictly observed by quasi-judicial authorities.
Case Details
Case Title: Rajesh Goyal Versus M/S Laxmi Constructions & Ors.
Citation: JURISHOUR-513-SC-2026
Case No.: Special Leave Petition (Civil) No.27184 of 2025
Date: 25/03/2026
Read More: Procedural Defects in Framing Charges Don’t Vitiate Trial Without Prejudice: Supreme Court
