Rajesh Goyal v. M/s Laxmi Constructions & Ors.

 Subordinate authority cannot reopen or nullify issues conclusively settled up to the Supreme Court; such orders are void for lack of jurisdiction and violate judicial discipline.

Background

Tenant repeatedly challenged eviction despite final orders up to Supreme Court and sought restoration before Rent Authority.

Eviction was ordered under s. 21(2) U.P. Urban Premises Rent Control Ordinance, 2021, affirmed by all forums including the Supreme Court. Despite finality and undertaking to vacate, the tenant filed a restoration application before the Rent Authority, which was allowed.

Issues Framed

  1. Whether a subordinate authority can entertain proceedings contrary to final orders of higher courts.
  2. Whether the Rent Authority had jurisdiction to reopen the matter on questions of title.

Court’s Reasoning

1. Finality of judicial proceedings

  • Rule: Orders affirmed up to the Supreme Court attain finality and are binding.
  • Application:
    • Tenant’s eviction and landlord-tenant relationship conclusively settled.
    • Subsequent restoration attempt amounts to abuse of process.
  • Holding: Proceedings were impermissible and an attempt to overreach SC orders.

2. Jurisdictional limits of Rent Authority

  • Statutory framework:
    • s. 21(2) UP Rent Ordinance, 2021 → eviction grounds.
    • s. 38 UP Rent Act, 2021 → jurisdiction confined to tenancy issues, not title.
  • Application:
    • Tenant raised title dispute (alleged forged sale deed).
    • Rent Authority acted beyond jurisdiction in entertaining such issues.
  • Holding: Order passed without jurisdiction → nullity.

3. Violation of judicial discipline

  • Rule: Subordinate authorities must follow binding decisions of higher courts.
  • Precedents:
    • Baradakanta Mishra v. Bhimsen Dixit (1973) 1 SCC 446
    • Union of India v. Kamlakshi Finance 1992 Supp (1) SCC 443
  • Application:
    • Authority ignored binding Supreme Court orders.
  • Holding: Such conduct undermines rule of law and judicial hierarchy.

4. Abuse of process and conduct of litigant

  • Application:
    • Multiple proceedings (SLP, review, misc., restoration) filed despite finality.
  • Holding: Gross abuse → costs of ₹5 lakhs imposed.

Decision / Disposition

  • SLP dismissed.
  • Restoration order dated 15.05.2025 declared void.
  • Costs imposed on tenant.
  • Show-cause notice issued to Rent Authority; apology accepted without further action.

Ratio

A subordinate authority lacks jurisdiction to reopen or undermine issues conclusively adjudicated up to the Supreme Court, and any such order—especially beyond its statutory domain—is a nullity and violative of judicial discipline.

Case Details

Citation: 2026 INSC 299
Decided on: 25 March 2026
Case Title: Rajesh Goyal v. M/s Laxmi Constructions & Ors.
Court: Supreme Court of India
Bench: Sanjay Karol, J.; N. Kotiswar Singh, J.


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