RAJESH GOYAL v. M/S LAXMI CONSTRUCTION
Judicial Discipline and Jurisdictional Limits - Subordinate Rent Authorities Cannot Overrule Final Eviction Orders Confirmed by the Supreme Court or Adjudicate Questions of Title.
Court: Supreme Court of India
Citation: 2026 INSC 299
Decision Date: 25-03-2026
List of Laws
U.P. Urban Premises Rent Control Ordinance, 2021; U.P. Urban Premises Rent Control Act, 2021; Doctrine of Binding Precedent; Principle of Judicial Discipline and Comity; Jurisdiction and Nullity of Orders; Registration Act, 1908; Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023
- Facts: The dispute arose from eviction proceedings initiated by a landlord against a tenant under the U.P. Urban Premises Rent Control Ordinance, 2021. The Rent Authority originally ordered eviction in 2022, a decision subsequently affirmed by the District Judge, the High Court, and finally the Supreme Court of India. The Supreme Court had granted the tenant time until March 31, 2025, to vacate, based on an undertaking. Despite these final orders, the tenant filed a restoration application before the Rent Authority (Additional District Magistrate) alleging that the landlord lacked proper title. The Rent Authority, acting on a report she herself had prepared in a different administrative capacity regarding alleged forgeries in the sale deeds, allowed the restoration and recalled the eviction order, effectively staying the Supreme Court's mandate.
- Procedural Posture: The landlord challenged the Rent Authority's restoration order before the Allahabad High Court via a Writ Appeal. The High Court set aside the restoration order and remitted the matter. The tenant then approached the Supreme Court via the present Special Leave Petition. Concurrent contempt proceedings were also active against the tenant for failing to vacate as per his previous undertaking.
- Issue: Whether a subordinate Rent Authority has the jurisdiction to recall an eviction order that has been affirmed by the High Court and the Supreme Court, and whether such authority can adjudicate upon questions of title?
- Holding: No, the Rent Authority acted without jurisdiction and in violation of judicial discipline. The order dated May 15, 2025, recalling the eviction is void and a nullity.
- Reasoning: The Court reasoned that once a judgment attains finality through the hierarchy of courts, it becomes a binding direction that cannot be compromised by a subordinate authority. The Rent Authority's jurisdiction under the U.P. Urban Premises Rent Control Act, 2021, is strictly limited to tenancy agreements and specifically excludes questions of title or ownership. Furthermore, the officer's action of using an administrative report prepared in one capacity to override a judicial mandate in another capacity was impermissible. The Court emphasized that judicial comity and discipline require subordinate authorities to follow orders of higher appellate authorities unreservedly. Disobedience to such orders undermines the rule of law and the dignity of the constitutional courts.
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