A statutory Rent Authority lacks jurisdiction to override or nullify a final eviction order affirmed by the Supreme Court. Judicial discipline requires that subordinate authorities strictly adhere to the hierarchical binding nature of superior court orders; any act violating such finality is a nullity.

Headnote:The dispute involves the attempted reopening of eviction proceedings by a tenant before a Rent Authority after the Supreme Court had already affirmed an eviction order and denied multiple review/miscellaneous applications. The Court analyzed the U.P. Urban Premises Rent Control Act, 2021, and the scope of the Rent Authority's jurisdiction, which is limited to tenancy agreements and excludes title disputes. The core issue was whether a Rent Authority, acting in a quasi-judicial capacity, could nullify a final order of the Supreme Court by entertaining restoration proceedings based on a separate extraneous report. The Court applied the principles of judicial discipline, emphasizing that subordinate authorities must follow the binding precedents and orders of superior courts. The ratio decidendi established that an order passed by a statutory authority lacking jurisdiction, specifically one that contradicts final orders of the Supreme Court, is a nullity. The appeal was dismissed, and the Rent Authority's order was declared void.

Table of Content
1. procedural history and finality of eviction litigation. (Para 1 , 2 , 4)
2. limited jurisdiction of rent authorities regarding title and binding nature of higher court orders. (Para 5 , 6 , 7 , 8 , 9)
3. invalidity of quasi-judicial orders passed without jurisdiction to undermine superior court rulings. (Para 10 , 11 , 12)
4. necessity of judicial discipline and integrity in subordinate judicial functions. (Para 13 , 14 , 15 , 16)

SANJAY KAROL J.

Leave Granted.

2. This appeal is at the instance of the tenant challenging the order and judgment passed in Writ Appeal No.8420 of 2025 by Signature Not Verified the High Court of Judicature at Allahabad dated 17^th July 2025, NAVEEN D Date: 2026.03.25 Reason:

allowing the landlord’s appeal thereby setting aside the order of the Additional District Magistrate (Administration), Saharanpur , allowing the petition for restoration of proceedings, preferred by the appellant.

3. Our order dated 22^nd September 2025 recorded the chequered history of this dispute, in detail. We may reproduce the same:

“…

2. The dispute pertains to Bungalow Hall Municipality No.2/1410/11 (Old No.43) Rose Bank, Ahmed Bagh/Chandranagar, Court Road, Saharanpur, Uttar Pradesh. Legal proceedings were initiated under Section 21(2) of the U.P. Urban Premises Rent Control Ordinance, 2021 which came to be numbered as Case No.2082/2022 titled “Ashish Kumar, son of Shri Laxmi Kumar vs. Harsh Goyal, son of Shri Virender Goyal”.

3. The Additional District Magistrate (Administration) Saharanpur-1 vide order dated 07.09.2022 held, relationship of landlord and tenant to be in existence inter se the parties and directed the tenant (appellant herein) to vacate the disputed property within 30 days. Such a finding was affirmed by the Appellate Authority viz., District Judge, Saharanpur in Rent Control Appeal No.57/2022 vide order dated 22.01.2024.

4. The High Court also by its order dated 14.05.2024 in “Matters under Article 227 No.1821/2024”, confirmed these findings. Not satisfied by having three Courts decide against him, the tenant tried his luck before this Court vide SLP(C)No.21177 of 2024 which was also dismissed on 20.09.2024 observing as under: -

1 Rent Authority

“1. After having heard learned counsel for the parties, we do not find any ground to interfere with the impugned judgment passed by the High Court. The Special Leave Petition is, accordingly, dismissed.

2. Learned counsel for the petitioners prays for minimum six months’ time to vacate the suit premises. In the facts and circumstances of the case, we direct that the suit premises shall be vacated by the petitioners on or before 31.03.2025 subject to payment of rent and arrears thereof. The petitioners shall hand over the vacant possession of the suit premises to the respondents on or before 31.03.2025 and shall not part with or create third party right therein. The petitioners shall file a usual undertaking in this regard within a period of two weeks from today before the Registrar, High Court of Judicature at Allahabad. The violation of the aforesaid terms would be treated as non-compliance of the order of this Court.

3. Pending interlocutory application(s), if any, is/are disposed of.

5. The tenant sought a review of the said order being Review Petition (C)Dy.No. 50976 of 2024 titled “Harsh Goyal & Anr. vs. M/s. Laxmi Construction & Ors.” which also was dismissed vide order dated

18.03.2025 in the following terms:-

“Delay condoned. IA No. 31347/2025 for listing review petition in open court is rejected. We have carefully perused the Review Petition as also the grounds taken in the petition. In our opinion, no case for review of order dated 20.09.2024 is made out. The Review Petition is, accordingly, dismissed. Pending application(s), if any, shall stand disposed of”

6. Obstinately, the tenant filed a Misc. Application bearing No.505 of 2025 in SLP (C) No. 21177 of 2024 against the dismissal of the Special Leave Petition as also the Review Petition. This was also

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2026 Supreme(Online)(SC) 1605

Sanjay Karol, Nongmeikapam Kotiswar Singh, JJRajesh Goyal – AppellantVersusLaxmi Constructions – RespondentCIVIL APPEAL NO. OF 2026 | SPECIAL LEAVE PETITION (CIVIL) NO.27184 OF 2025

Cases Referred (2)

Sanjay Karol, Nongmeikapam Kotiswar Singh, JJ
Rajesh Goyal – Appellant
Versus
Laxmi Constructions – Respondent
CIVIL APPEAL NO. OF 2026 | SPECIAL LEAVE PETITION (CIVIL) NO.27184 OF 2025