The Supreme Court has issued a significant ruling clarifying that High Courts cannot re-examine evidence under Article 227 when legal heirs seek to amend eviction cases. According to the latest Supreme Court judgment, the court held that the High Court exercising its jurisdiction under Article 227 of the Constitution erred in interfering with the Appellate Bench's decision to grant amendment to the plaint. The ruling establishes important procedural limits for High Courts in supervising lower court decisions, particularly regarding eviction cases involving deceased landlords.
The ruling stems from a specific case involving a 188 square feet shop in Mumbai owned by Raghunath Gopal Deshmukh. As reported by Mint, the landlord had filed an eviction suit in 2005 against tenants, claiming the premises were needed for his 'bonafide use, occupation and enjoyment for himself and his family members'. The tenant opposed this request, arguing that the eviction was originally based only on the landlord's personal need and could not be changed later. The case progressed through multiple levels, with the Appellate Bench initially allowing amendment to include the legal heirs' bonafide need, but this was subsequently set aside by the High Court.
According to Mint reports, legal heirs are those who have the legal right to inherit assets and property of a deceased person, including close family members such as spouses, children, or parents. The court noted that once legal heirs step into the landlord's place in the case, they should be allowed to furnish their own requirements. The latest Supreme Court judgment emphasizes that subsequent events have material significance on the relief of parties and that courts are justified in bending procedural rules where no specific provision or fairplay is violated. This principle was applied to allow the legal heirs to substantiate their bonafide need for the property.
As reported by Mint, the Supreme Court allowed legal heirs to update eviction cases to include their own bonafide need for the property. The latest judgment clarifies that an amendment to the plaint does not depend on whether the case will eventually succeed in trial, citing the precedent of Raj Kumar Bhatia v. Subhash Chander Bhatia 2017 INSC 1240. The Supreme Court emphasized that Article 227 restricts the High Court to examine whether lower courts have acted within their jurisdiction and cannot act as an Appellate Court to review or reassess evidence. This procedural limitation ensures that High Courts cannot interfere with factual determinations made by lower courts.
