IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH **** 124 CR-3783-2026 Date of Decision.:05.05.2026 Ranjeeta Gandhi …..Pe--oner Vs. Sharda Devi and Others .….Respondents CORAM:- HON'BLE MR. JUSTICE DEEPAK GUPTA Present:- Ms. Inderpal Kaur, Advocate for Mr. Ajay Ghangas, Advocate for the peoner. **** DEEPAK GUPTA, J. (ORAL) The present revision peon has been preferred by the peoner–applicant assailing the order dated 14.10.2025 (Annexure P-6) passed by the learned Rent Controller, Faridabad, whereby her applicaon under Order 1 Rule 10 read with Secon 151 CPC for impleadment in the pending evicon peon has been dismissed. 2. The brief facts necessary for adjudicaon of the present revision are that an evicon peon under the Haryana Urban (Control of Rent & Evicon) Act, 1973 is pending between the landlord and the tenant. During the pendency of the said proceedings, the peoner–applicant moved an applicaon seeking her impleadment as a party on the ground that she is the owner of the suit property by virtue of a family se=lement and, therefore, the peoner in the evicon peon has no right to maintain the proceedings. 3. The said applicaon was contested by the landlord on the ground that the proceedings before the Rent Controller are summary in nature and are confined to determinaon of the relaonship of landlord NEETIKA TUTEJA 2026.05.07 16:27 I attest to the accuracy and integrity of this document CR-3783-2026 and tenant and the existence of statutory grounds for evicon. It was further contended that disputes relang to tle or ownership cannot be adjudicated in rent proceedings and, therefore, the applicant is neither a necessary nor a proper party. 4. The learned Rent Controller, a?er considering the rival submissions and the legal posion, dismissed the applicaon holding that the applicant, who is claiming tle in the property, cannot be impleaded in evicon proceedings as the queson of tle is not germane for adjudicaon before the Rent Controller and that only the landlord and tenant are necessary pares to such proceedings. 5. Assailing the above order, learned counsel for the peoner– applicant contends that the impugned order suffers from illegality as the applicant is the real owner of the property and her presence is necessary for effecve adjudicaon of the dispute. It is argued that non-impleadment of the applicant would result in mulplicity of proceedings and prejudice to her rights. 6. I have heard learned counsel for the peoner and have perused the record. 7. At the outset, it is to be noted that the scope of interference in revisional jurisdicon is limited and this Court would interfere only where the order impugned suffers from patent illegality, material irregularity or jurisdiconal error. 8. The controversy in the present case revolves around the scope of impleadment under Order 1 Rule 10 CPC in the context of rent proceedings. It is well se=led that a party can be impleaded only if it is either a necessary party, without whom no effecve decree can be passed, or a proper party whose presence is required for complete and effecve adjudicaon of the issues involved. Page No. 2 of 4 Pages NEETIKA TUTEJA 2026.05.07 16:27 I attest to the accuracy and integrity of this document CR-3783-2026 9. In evicon proceedings under the Rent Act, the jurisdicon of the Rent Controller is confined to examining two essenal aspects, namely, the existence of relaonship of landlord and tenant and the existence of statutory grounds for evicon. Quesons relang to tle or ownership of the property fall outside the purview of such proceedings and are required to be adjudicated by a competent civil court. 10. In the present case, the claim of the peoner–applicant is founded enrely on her alleged ownership of the suit property on the basis of a family se=lement. Such a claim squarely raises a dispute of tle, which cannot be gone into in rent proceedings. The learned Rent Controller has rightly held that the applicant is neither a necessary nor a proper party, as her presence is not required for adjudicaon of the issues involved in the evicon peon. 11. It is also a se=led principle that the landlord is dominus lis and cannot be compelled to implead a third party unless such party is able to demonstrate that without its presence, no effecve adjudicaon is possible. In the present case, even if the applicant is not impleaded, the Rent Controller would sll be competent to decide the evicon peon on the basis of the relaonship of landlord and tenant and the grounds pleaded therein. 12. The contenon regarding avoidance of mulplicity of proceedings is also misconceived, as the applicant has an independent remedy to seek declaraon of her rights before the competent civil court. 13. The learned Rent Controller has relied upon se=led legal principles, including the proposion that in evicon proceedings, the landlord and tenant alone are necessary pares and that disputes of tle are irrelevant for such proceedings. The reasoning recorded by the Rent Controller is sound and does not suffer from any infirmity. Page No. 3 of 4 Pages NEETIKA TUTEJA 2026.05.07 16:27 I attest to the accuracy and integrity of this document CR-3783-2026 14. No jurisdiconal error, illegality or perversity has been pointed out in the impugned order so as to warrant interference by this Court in exercise of revisional jurisdicon. 15. Consequently, the present revision peon is dismissed being devoid of merit. 16. However, it is clarified that the dismissal of the applicaon for impleadment shall not preclude the peoner–applicant from availing her remedies in accordance with law before the competent civil court for adjudicaon of her alleged rights in the property. (DEEPAK GUPTA) JUDGE May 05, 2026 Neeka Tuteja Whether Speaking/reasoned Yes/No Whether Reportable Yes/No Page No. 4 of 4 Pages NEETIKA TUTEJA 2026.05.07 16:27 I attest to the accuracy and integrity of this document