Punjab & Haryana High Court Dismisses Landlord’s Revision Against Rejection of Additional Evidence; Says Mutation and Sale Deed Not Material to Eviction Dispute
Case Name: Ravinder Singh Gulati @ Ravinder Singh v. M/s Mahalaxmi Glass Trading Co. & Another
Date of Judgment: October 31, 2025
Citation: CR-7728-2025
Bench: Hon’ble Ms. Justice Mandeep Pannu
Held: The Punjab & Haryana High Court dismissed a revision petition filed by a landlord challenging the Rent Controller’s refusal to accept additional documents—mutation and sale deed—at the stage of final arguments. Justice Mandeep Pannu held that such documents were neither indispensable to adjudication nor beyond the petitioner’s prior knowledge, observing that mutation entries do not confer ownership rights and that the sale deed of an adjoining shop was irrelevant to the tenancy dispute. The Court further ruled that permitting additional evidence after closure of evidence would unfairly delay proceedings and allow the party to fill gaps in its case.
Summary: The petitioner filed an eviction petition under Section 13 of the Haryana Urban (Control of Rent and Eviction) Act, 1973, seeking to evict the tenant from premises at Model Town, Karnal, on the grounds of non-payment of rent and impairment of property value. During final arguments, the petitioner sought to produce two documents — (i) mutation No. 740 based on a Will, and (ii) sale deed No. 7091/1 dated 21.12.2020 concerning an adjoining shop. The Rent Controller rejected the application, noting that both documents were within the petitioner’s knowledge, immaterial to the tenancy issue, and introduced belatedly to fill lacunae.
On revision, the High Court upheld this view, reiterating that the power to admit additional evidence under Section 151 CPC is discretionary and can only be exercised when due diligence is shown or when the evidence is indispensable for justice. Citing established principles, the Court clarified that mutation entries are merely revenue records and do not affect ownership, while the sale deed of another property does not establish a landlord-tenant relationship for the demised premises. Justice Pannu held that reopening evidence at the stage of final arguments would defeat procedural discipline and fairness.
Decision: The Court dismissed the civil revision petition, holding that the Rent Controller’s order dated 08.10.2025 was well-reasoned and legally sound. It directed that the eviction petition be decided independently on merits without being influenced by any observation in this order.