In the Tamil Nadu Regulation of Rights and Responsibilities of Landlords and Tenants Act, 2017, cross-examination is not an automatic right but requires judicial discretion and sufficient cause, especially where the landlord-tenant relationship is admitted, to fulfill the legislative mandate of summary, expedited proceedings.

Headnote:The proceedings concern the interpretation of the Tamil Nadu Regulation of Rights and Responsibilities of Landlords and Tenants Act, 2017, specifically addressing the necessity of cross-examination in summary eviction proceedings. The trial court had granted an order for cross-examination of a witness in a routine manner, despite a clear admission of the jural relationship between the landlord and tenant, and the absence of a registered tenancy agreement. The court determined that cross-examination under the Act is not a matter of right but is subject to judicial discretion, requiring sufficient cause to be recorded before being permitted. The central issue is whether the trial court acted erroneously in mechanically ordering the cross-examination of a witness in a summary proceeding. The court reasoned that in instances where the landlord-tenant relationship is admitted and statutory mandates for tenancy documentation are absent, the objective of the Act—expedited disposal—is undermined by routine delays. Consequently, the impugned order permitting cross-examination without specific justification was held to be unsustainable in law. In the result, the Civil Revision Petition is allowed, the order of the trial court is set aside, and the court below is directed to dispose of the matter expeditiously.

Table of Content
1. overview of the petition, the nature of the proceedings, and the statutory framework regarding witness cross-examination. (Para 1 , 2 , 3)
2. necessity for judicial discretion in permitting cross-examination to uphold the summary nature of tenancy litigation. (Para 4)

ORDER

This Civil Revision Petition has been filed seeking to set aside the order dated 23.03.2026 passed in R.L.T.O.P. No. 4 of 2024 on the file of the z District Munsif Court, Sriperumbudur, and consequently, to direct the court below to post the matter for final arguments.

2. The learned counsel for the petitioner submits that the petitioner filed R.L.T.O.P. No. 4 of 2024 seeking recovery of possession of the leased premises. It is contended that under the Tamil Nadu Regulation of Rights and Responsibilities of Landlords and Tenants Act, 2017 (hereinafter referred to as 'the Act'), cross-examination of witnesses is not a matter of right but is subject to the discretion of the Court upon a choosing of sufficient cause. However, the Trial Court erred in routinely posting the matter for the cross-examination of P.W.1, and the impugned order is liable to be set aside.

3. A perusal of the e-Court status and records of R.L.T.O.P. No. 4 of 2024 reveals that through P.W.1, documents Ex.P1 to Ex.P8 were marked, and no further evidence was adduced. Thereafter, the Trial Court adjourned the matter for the cross-examination of P.W.1. Under the provisions of the Act, cross- examination is not mandatory and may be permitted only at the discretion of the Court, provided sufficient reasons are recorded.

4. In the counter-objection filed below, the respondent has expressly admitted the jural relationship of landlord and tenant. Furthermore, it is undisputed that no new tenancy agreement has been executed between the parties as mandated by law. Therefore allowing cross-examination in a routine, conditional manner without assigning specific reasons is unsustainable. The Trial Court has adjourned the case for cross-examination in a mechanical manner, which defeats the objective of expedited summary proceedings under the Act. Consequently, the order dated 23.03.2026 is liable to be set aside. 5. Accordingly, the order dated 23.03.2026 passed in R.L.T.O.P. No. 4 of

2024 is set aside, and the Trial Court is directed to dispose of the same expeditiously.

6. In the result, this Civil Revision Petition is allowed. No costs.

Connected pending petitions, if any, are closed.

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2026 Supreme(Online)(Mad) 42194

IN THE HIGH COURT OF JUDICATURE AT MADRAST.V. Thamilselvi, JP.V. Thendralvanan – AppellantVersusG. Vijayakumar – RespondentCivil Revision Petition | R.L.T.O.P. No. 4 of 2024

IN THE HIGH COURT OF JUDICATURE AT MADRAS
T.V. Thamilselvi, J
P.V. Thendralvanan – Appellant
Versus
G. Vijayakumar – Respondent
Civil Revision Petition | R.L.T.O.P. No. 4 of 2024