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Punjab-Haryana High Court

Narinderpal Singh vs Geetika And Ors on 11 February, 2026

Author: Pankaj Jain

Bench: Pankaj Jain

DEEPAK KUMAR
2026.02.13 14:26

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IN THE HIGH COURT OF PUNJAB AND HARYANA
AT CHANDIGARH

CR-4669-2024 (O&M)
Date of decision : 11.02.2026

NARINDERPAL SINGH .... Petitioner

Versus

GEETIKA AND ORS
...Respondents

CORAM: HON'BLE MR. JUSTICE PANKAJ JAIN Present: Mr. Vivek Thakur, Advocate for the petitioner. Mr. Shubham Thakur, Advocate for respondent No.2.

Present revision petition is directed against order dated 24.05.2024 passed by Rent Controller, Kapurthala, whereby application filed by respondent No.2 claiming himself to be co-owner in the demised premises, has been allowed and he has been ordered to be impleaded as petitioner invoking Order | Rule 10 CPC.

2. The landlord filed eviction petition against the tenant. During the pendency of the same, present application was filed by respondent No.2 namely Raman Kumar Wadhwa claiming that his mother namely Chand Rani was co-sharer in the demised premised as she purchased the same along with petitioner Geetika vide sale deed dated 05.12.2011. Chand Rani expired on 21.02.2020. After death of Chand Rani, the property having devolved upon the applicant and he having become co-sharer in the demised I attest to the accuracy and integrity of this document CR-4669-2024 premises, is entitled to be impleaded as petitioner along with Geetika. The application though was supported by Geetika, but was opposed by respondent/tenant denying his relationship with the proposed petitioner. The Rent Controller allowed the application filed under Order I Rule 10 CPC impleading applicant Raman Kumar Wadhwa as one of the petitioners in the eviction proceedings.

3, Ld. counsel for the petitioner has assailed the order passed by the Rent Controller submitting that for the purpose of eviction proceedings only landlord and tenant are the necessary parties. The applicant having no relationship with the tenant, he cannot be allowed to be impleaded as a party. It has been further contended that the applicant being neither necessary nor proper party, Rent Controller erred in exercising power under Order I Rule 10 CPC. Reference is being placed upon ration of law laid down in the case of Kanaklala Das and others vs. Naba Kumar Das and others, (2018) 2 SCC 352.

4, Per contra, counsel for respondent No.2 (applicant under Order I Rule 10 CPC) would submit that the admitted fact being that Geetika along with Chand Rani were co-sharers in the suit property and Chand Rami having died during the pendency of the eviction petition, the respondent/applicant Raman Kumar Wadhwa has been rightly impleaded as party by the Rent Controller.

DEEPAK KUMAR 2026.02.13 14:26 CR-4669-2024 -3-

5. I have heard counsel for the parties and have gone through records of the case.

6. The challenge to the order allowing application under Order I Rule 10 has been raised at the behest of the tenant. In the considered opinion of this Court, tenant has no /ocus to question the impleadment of one of the co-owners in the eviction proceedings. Co-owner of the applicant who filed eviction petition is dominus litis, she has no objection to the impleadment of co-sharer. Respondent/tenant cannot question the inclusion of co-sharer as to petitioner in eviction proceedings..

7. Under the Punjab Rent Act, 1995 'landlord' has been defined under Section 2(c) which reads as under:

"2(c) "Landlord" means a person who, for the time being is receiving or is entitled to receive the rent of any premises, whether on his own account or on account of or on behalf of, or for the benefit of any other person or as a trustee, guardian or receiver for any other person or who would so receive the rent or be entitled to receive the rent, if the premises were let to a tenant;"

8. The definition is inclusive and is not exclusive in nature. Though, trite it is that landlord may not be a title holder but the right of a paramount title holder being a landlord, is beyond question. After death of Chand Rani, the present applicant claiming to be one of the co-sharers is not only proper but necessary party.

9. In view thereof, this Court finds that the Rent Controller rightly allowed the application filed by respondent No.2.

CR-4669-2024

10. Finding no merit in the present revision petition, the same is ordered to be dismissed.

11, Pending application, if any, shall also stands disposed off. February 11, 2026 (Pankaj Jain) Dpr Judge Whether speaking/reasoned -- : Yes/No Whether reportable : Yes/No DEEPAK KUMAR 2026.02.13 14:26 I attest to the accuracy and integrity of this document