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Civil Property & InheritanceSupreme Court of India

Rajesh Goyal v. M/S Laxmi Constructions and Ors.

Civil Appeal · 2026 INSC 299Decided 25 Mar 2026
C.A. No.-004076-004076 - 2026 (arising out of SLP(C) No.27184/2025)
Justice Sanjay Karol · Justice Nongmeikapam Kotiswar Singh · Justice Augustine George Masih

Background

A tenant in Saharanpur, Uttar Pradesh, had already lost an eviction dispute at every level: the Rent Authority, the appellate District Judge, the High Court, and finally the Supreme Court itself, which had dismissed his SLP, review petition, and a further miscellaneous application, directing him to vacate by 31 March 2025. Instead of complying, the tenant filed a fresh "restoration application" before the very same Rent Authority (an Additional District Magistrate), who, acting in a separate capacity as an investigating authority looking into allegedly forged sale deeds, allowed the restoration and effectively reopened a matter the Supreme Court had already closed. The landlord successfully challenged this before the High Court, and the tenant then approached the Supreme Court again.

Decision Breakdown

The Supreme Court refused to entertain the tenant's fresh petition, calling it a gross abuse of process and an attempt to overreach the Court's own final orders, and imposed a Rs. 5 lakh cost payable to the Supreme Court Middle Income Group Legal Aid Society (recorded in an earlier order dated 22 September 2025). It also issued a show-cause notice to the Additional District Magistrate/Rent Authority for entertaining and allowing the restoration application in apparent disregard of the Supreme Court's own prior orders. In this final judgment, the Court held that the officer, in her capacity as Rent Authority, had no jurisdiction to set aside her own findings/report rendered in her separate capacity as Additional District Magistrate investigating a criminal complaint: an order passed without jurisdiction is a nullity, so the recall order dated 15 May 2025 was declared void. Having received an unconditional apology from the officer, the Court accepted it and clarified this would not affect her career progression, while reiterating the importance of judicial discipline and adherence to the finality of higher court orders.

Lesson Learnt

Once a dispute has been conclusively decided up to the Supreme Court, a litigant cannot revive it through a fresh application before a lower authority, doing so is treated as an abuse of process and can attract heavy costs. Statutory authorities must also stay within the specific jurisdiction conferred on them and cannot use findings from one official capacity to override binding orders of a court while acting in another capacity.

Rajesh Goyal v. M/S Laxmi Constructions and Ors. – Legal Case Shots | LegalAware