Facts: The Applicants (owners) leased an open plot in Bandra to one Moogatlal in 1934. Moogatlal constructed temporary structures (Galas) and inducted third parties (Obstructionists). After various lease renewals and Moogatlal’s death, a third lease was executed in 1959 in favour of only three of his heirs, following a surrender of rights by all fifteen original heirs. This 1959 lease contained a specific covenant requiring the tenants to remove all structures and return the land in its original vacant state upon expiry. After the protection for open land under rent control laws ceased with the Maharashtra Rent Control Act, 1999, the owners filed an ejectment suit against the surviving heirs of the 1959 lessees. A consent decree was passed in 2006 for the recovery of possession. However, when the decree was put into execution, the occupants of the Galas (Respondents 1-6) obstructed, claiming independent rights as lawful sub-tenants.Procedural Posture: The Trial Court (Small Causes Court) allowed the Obstructionist Notice, directing the ouster of the occupants. On appeal, the Appellate Bench of the Small Causes Court reversed this decision, holding the decree to be "incomplete" and "inexecutable" because it was based on a surrender by only a few heirs, assuming fifteen independent tenancies existed. The owners challenged this reversal through Civil Revision Applications before the Bombay High Court.Issue: Whether the obstructionists, inducted into structures built by a lessee on a lease of open land, possess any independent statutory right to resist a decree for possession passed against the main lessee; and whether the execution court can go behind a consent decree to determine its validity based on the number of heirs who signed it.Holding: No, the obstructionists have no independent right to occupy the land once the main lease is terminated. The High Court set aside the Appellate Bench's order and restored the Trial Court's judgment, confirming the ouster of the obstructionists.Reasoning: The Court reasoned that the 1959 lease was specifically for open land and the definition of "tenant" therein limited the rights to the last surviving heirs of the three named lessees. The Appellate Bench committed a "perverse" error by assuming fifteen independent tenancies remained. Legally, when a lease is for open land, any structure built by the lessee is at the lessee's risk. Occupants inducted into such structures by the lessee are merely licensees vis-a-vis the owner of the land. Under the principle of "dual ownership", the termination of the land lease automatically ends the right of occupants in the superstructures to remain on the land. Furthermore, under Order XXI Rule 101, an execution court cannot reopen a decree or redetermine issues between the original parties; it must focus on whether the obstructionist has an independent legal title, which the respondents failed to prove.