Rajesh Goyalv.Ms Laxmi Constructions & Ors

Synopsis

This judgment deals with a case of gross abuse of process of court by a tenant who, after exhausting all remedies up to the Supreme Court (including dismissal of SLP, review, and miscellaneous applications), filed a restoration application before the Rent Authority, which was allowed. The High Court set aside that restoration order. The Supreme Court dismissed the tenant’s appeal and, in addition, issued a show cause notice to the Rent Authority (Additional District Magistrate) for having entertained and allowed the restoration application despite the finality of the earlier judicial orders. The Court declared the Rent Authority’s order void for lack of jurisdiction and for violating judicial discipline. The officer tendered an unconditional apology, which was accepted, with a clarification that the proceedings would not affect her career progression. The judgment reiterates the principles of judicial discipline, the binding nature of higher court orders, and the limits of the jurisdiction of Rent Authorities under the UP Urban Premises Rent Control Act.

2. Basic Information of the Judgment

Case Title: Rajesh Goyal vs. M/s Laxmi Constructions & Ors.

Civil Appeal No.: Arising out of SLP (Civil) No. 27184 of 2025

Bench: Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh

Judgment Author: Justice Sanjay Karol

Date of Decision: March 25, 2026

Citation: 2026 INSC 299

Appeal From: Judgment and order dated 17.07.2025 of the High Court of Judicature at Allahabad in Writ Appeal No. 8420 of 2025, which had set aside the order of the Additional District Magistrate (Administration), Saharanpur dated 15.05.2025 allowing a restoration application filed by the tenant.

3. Legal Framework

This judgment involves the interpretation of the UP Urban Premises Rent Control Act, 2021 (and the Ordinance), the limits of the jurisdiction of Rent Authorities, the principle of judicial discipline, and the doctrine that an order passed without jurisdiction is a nullity.

A. Key Provisions of Law:

• U.P. Urban Premises Rent Control Ordinance, 2021 / U.P. Urban Premises Rent Control Act, 2021:
  Section 21(2): Empowers the Rent Authority to order eviction on grounds including non‑payment of rent.
  Section 38: Provides that no Civil Court shall entertain any suit relating to the provisions of the Act, and the jurisdiction of the Rent Authority is limited to matters relating to the tenancy agreement and does not extend to questions of title or ownership.

• Code of Civil Procedure, 1908:
  Section 11: Res judicata – principles of finality of judgments.

• Constitution of India:
  Article 136: Special leave jurisdiction of the Supreme Court.
  Article 141: Law declared by the Supreme Court is binding on all courts within the territory of India.

B. Related Precedents (Discussed in the Judgment):

• Baradakanta Misra v. Bhimsen Dixit (1973) 1 SCC 446: Held that deliberate and mala fide conduct of not following the law laid down by a superior court undermines constitutional authority and the rule of law.

• Union of India v. Kamlakshi Finance Corpn. Ltd. (1992) Supp (1) SCC 105: Principles of judicial discipline require that orders of higher appellate authorities be followed unreservedly by subordinate authorities.

• C. Ravichandran Iyer v. Justice A.M. Bhattacharjee (1995) 5 SCC 457: Emphasised that judges must maintain high standards of conduct, integrity, and probity, and that any conduct undermining public confidence in the judiciary is deleterious.

• M.A. Murthy v. State of Karnataka (2003) 7 SCC 517: Doctrine of binding precedent promotes certainty, consistency, and enables organic development of law.

4. Relevant Facts of the Case

1. Eviction Proceedings: The landlord (M/s Laxmi Constructions) filed an application under Section 21(2) of the UP Urban Premises Rent Control Ordinance, 2021 (Case No. 2082/2022) against the tenant (Harsh Goyal and Rajesh Goyal). The Additional District Magistrate (Administration), Saharanpur, by order dated 07.09.2022, held that a landlord‑tenant relationship existed and directed eviction.

2. Appeals and Affirmations: The tenant’s appeal before the District Judge (Rent Control Appeal No. 57/2022) was dismissed on 22.01.2024. A petition under Article 227 before the Allahabad High Court (Matters under Article 227 No. 1821/2024) was dismissed on 14.05.2024.

3. Supreme Court Proceedings: The tenant filed SLP (C) No. 21177/2024, which was dismissed on 20.09.2024 with a direction to vacate by 31.03.2025, subject to payment of rent. The tenant sought review (dismissed on 18.03.2025) and thereafter a miscellaneous application (dismissed on 24.03.2025).

4. Restoration Application: Despite the finality, the tenant filed a restoration application before the same Additional District Magistrate (the Rent Authority), which was allowed by order dated 15.05.2025. The Authority relied on a report it had prepared in a separate capacity (as Additional District Magistrate) regarding alleged forgery of sale deeds.

5. High Court Intervention: The landlord challenged the restoration order in Writ Appeal No. 8420/2025. The High Court allowed the appeal on 17.07.2025, setting aside the restoration order and remanding the matter for fresh decision in accordance with law.

6. Contempt Proceedings: Parallelly, the landlord initiated contempt proceedings before the Supreme Court for non‑compliance of the eviction order. The Supreme Court recorded an undertaking by the tenant to vacate.

7. Appeal to Supreme Court: The tenant filed the present SLP against the High Court’s order. The Supreme Court, while dismissing the SLP, also issued a show cause notice to the Additional District Magistrate for having entertained the restoration application in disregard of the binding orders of the Supreme Court and the High Court.

5. Issues Identified by the Supreme Court

1. Whether the Additional District Magistrate (Rent Authority) had jurisdiction to entertain a restoration application seeking to reopen the eviction proceedings after the matter had been finally decided by the Supreme Court and after the tenant had given an undertaking to vacate.

2. Whether the order of the Rent Authority allowing restoration was without jurisdiction and a nullity.

3. Whether the Rent Authority’s action amounted to a violation of judicial discipline, requiring intervention by the Supreme Court.

4. What consequences should follow for the Rent Authority for having passed an order in defiance of the binding orders of the superior courts.

6. Ratio Decidendi (The Reasoning and Decision of the Court)

The Supreme Court dismissed the appeal and declared the Rent Authority’s restoration order void. The reasoning is as follows:

• Finality of Judicial Orders: The landlord‑tenant relationship and the eviction order had been affirmed by the District Judge, the High Court, and finally by the Supreme Court, which had dismissed the SLP and granted time to vacate. The tenant had exhausted all remedies, including review and miscellaneous applications. Therefore, the issue attained finality.

• Rent Authority’s Limited Jurisdiction: Under Section 38 of the UP Urban Premises Rent Control Act, 2021, the Rent Authority’s jurisdiction is confined to the tenancy agreement and does not extend to questions of title or ownership. The restoration application was based on an allegation that the landlord’s sale deed was forged, which is a question of title outside the Authority’s jurisdiction.

• Self‑Created Conflict of Roles: The Additional District Magistrate, in a separate capacity, had prepared a report on the alleged forgery. She then, in her capacity as Rent Authority, relied on that same report to allow the restoration application. The Court held that this was impermissible and amounted to exercising jurisdiction beyond what the statute permitted.

• Nullity of Order: An order passed without jurisdiction is a nullity. The Rent Authority lacked jurisdiction to reopen the eviction proceedings after the Supreme Court’s final order. Therefore, the order dated 15.05.2025 was declared void.

• Violation of Judicial Discipline: The Rent Authority’s action was in direct disregard of the binding orders of the High Court and the Supreme Court. The Court reiterated that subordinate authorities must unreservedly follow the orders of higher courts. Any deliberate deviation undermines the rule of law.

• Acceptance of Apology: The Rent Authority tendered an unconditional apology. The Court accepted it, but clarified that the proceedings would not affect her career progression. The Court, however, issued a stern reminder about the importance of judicial discipline.

7. New Legal Principles Established / Reiterated

1. Finality of Supreme Court Orders: Once the Supreme Court dismisses an SLP and grants time to vacate, the matter attains finality. No subordinate authority can reopen the proceedings on grounds that were or could have been raised earlier.

2. Limited Jurisdiction of Rent Authorities: Under the UP Urban Premises Rent Control Act, 2021, the Rent Authority cannot adjudicate on title. Any order based on an allegation of title, especially after a final eviction decree, is without jurisdiction.

3. Judicial Discipline and Comity: Subordinate courts and authorities are bound by the decisions of superior courts. Disobedience, even if not mala fide, undermines the hierarchy of courts and the rule of law.

4. Nullity of Orders Without Jurisdiction: An order passed by an authority acting beyond its statutory powers is a nullity and can be declared void even in collateral proceedings.

5. Doctrine of Res Judicata in Rent Matters: Once the landlord‑tenant relationship is conclusively established in proceedings under the Rent Control Act, it cannot be re‑litigated in the same forum after all appeals have been exhausted.

8. The Court’s Analysis and Examination of Concepts

• Exhaustion of Remedies: The Court meticulously traced the history of the case, noting that the tenant had lost before the Rent Authority, the Appellate Authority, the High Court, and the Supreme Court. The dismissal of the SLP with a time‑bound direction to vacate was a final order. The subsequent restoration application was a blatant attempt to circumvent that finality.

• Role of the Rent Authority: The Court examined Section 38 of the Act and held that the Rent Authority’s jurisdiction is narrowly defined. It cannot sit in judgment over the title of the landlord. The tenant’s allegation of forgery was a title dispute that could only be agitated in a civil court, not before the Rent Authority.

• Conflict of Interest: The Court noted that the same officer had prepared a report in an administrative capacity and then, as Rent Authority, relied on that report to allow restoration. This blurred the lines between administrative and quasi‑judicial functions and was a clear overreach.

• Judicial Discipline: The Court quoted earlier decisions to emphasise that the principle of judicial discipline requires all courts and authorities to respect the finality of orders of superior courts. The Rent Authority’s order, being in defiance of the Supreme Court’s order, was an affront to the rule of law.

• Apology and Consequences: The Court accepted the unconditional apology but made it clear that such conduct would not be tolerated in the future. The clarification that the proceedings would not affect the officer’s career progression was a measure of leniency, but the judgment serves as a warning to all judicial and quasi‑judicial officers.

9. Critical Analysis of the Judgment

• Strength – Upholding Finality: The judgment strongly reinforces the principle of finality of judgments, especially after the Supreme Court has spoken. It prevents litigants from endlessly re‑litigating the same issue through different forums.

• Clarity on Jurisdictional Limits: By declaring the Rent Authority’s order a nullity, the Court provides clear guidance on the scope of the Rent Authority’s powers under the 2021 Act. This will prevent similar overreach in the future.

• Judicial Discipline: The Court’s strong language on judicial discipline serves as a reminder to all subordinate courts and tribunals that they must adhere to the hierarchy of courts and respect final orders.

• Leniency Shown: While issuing a show cause notice, the Court accepted the unconditional apology and clarified that the officer’s career would not be affected. This balances the need for accountability with a practical approach, especially since the officer might have acted out of a mistaken belief rather than deliberate defiance.

• Potential Critique – No Punishment: Some might argue that the officer should have faced disciplinary consequences for ignoring the Supreme Court’s final order. However, the Court’s acceptance of the apology, coupled with the strong observations, is likely to have a deterrent effect.

• Impact on Rent Litigation: The judgment will discourage tenants from filing frivolous restoration applications after final eviction orders. It also clarifies that title disputes cannot be used to frustrate rent control proceedings.

10. Final Outcome

The Supreme Court dismissed the tenant’s appeal, upholding the High Court’s order. It declared the order of the Additional District Magistrate (Rent Authority) dated 15.05.2025 as void and without jurisdiction. The show cause notice issued to the Rent Authority was disposed of after the officer tendered an unconditional apology, which was accepted with the clarification that the proceedings would not affect her career progression. The Court reiterated the principles of judicial discipline and finality of judgments. No order as to costs.

11.  (MCQs)

1. Under the UP Urban Premises Rent Control Act, 2021, the Rent Authority’s jurisdiction is limited to:?
a) Determining title to the property.
b) Matters relating to the tenancy agreement, and does not extend to questions of title.
c) Deciding all disputes between landlord and tenant, including criminal allegations.
d) Hearing appeals from civil courts.

2. The Supreme Court declared the Rent Authority’s restoration order void primarily because:?
a) It was passed without giving notice to the landlord.
b) The Rent Authority had no jurisdiction to reopen the matter after the Supreme Court’s final order and because it lacked jurisdiction over title disputes.
c) The tenant had not paid the costs.
d) The order was not signed by the District Magistrate.

3. Which of the following principles was NOT a basis for the Court’s decision?
a) Judicial discipline requires subordinate authorities to follow higher court orders.
b) An order passed without jurisdiction is a nullity.
c) A tenant has an absolute right to file a restoration application at any time.
d) The doctrine of res judicata applies.

4. The Court accepted the unconditional apology of the Additional District Magistrate and clarified that:?
a) She would be suspended from service.
b) The proceedings would not affect her career progression.
c) She would be transferred immediately.
d) She must pay a fine of ₹5 lakhs.