The Supreme Court of India on September 10, 2025, granted a temporary reprieve to the GMR Group and its Chairman & Managing Director (CMD) by staying the Delhi High Court order that had directed their eviction from a sprawling farmhouse in Pushpanjali Farms, New Delhi. The property, spread over 3.81 acres and featuring a luxurious 30,000-square-foot residence, outhouse, landscaped lawns, and a swimming pool, has become the subject of a complex legal battle involving questions of tenancy rights, lease validity, applicability of the Delhi Land Reforms Act (DLR Act), and the rights of a new property owner.
Supreme Court Intervention
A Bench of Justices Aravind Kumar and NV Anjaria passed the interim stay order, observing that the matter required further examination. The Court issued notice and listed the case for the next hearing on October 29, 2025.
“Issue notice. Stay. List on October 29,” the Bench stated while restraining the eviction.
Senior Advocates Dr. Abhishek Manu Singhvi and Mukul Rohatgi, appearing for Delhi International Airport Limited (DIAL) and GMR entities, argued that the case was not suitable for a summary judgment as delivered by the Delhi High Court. They contended that at least seven triable issues were raised in the matter, which necessitated a full-fledged trial.
On the other side, Senior Advocates PS Patwalia and C. Aryama Sundaram, representing the new owner Onkar Infotech, opposed the stay. They argued that after the transfer of ownership, the new landlord was entitled to possession of the property and intended to personally reside in it.
Background of the Dispute
The farmhouse, known as Bijwasan, was originally leased by Indus Sor Urja to three GMR companies, with a fourth affiliate later stepping in to pay rent. The lease covered 2.45 acres of the 3.81-acre property, housing the main building.
- Initial rent: ₹39.67 lakh per month (plus GST)
- Revised rent: Approximately ₹45.62 lakh per month
- Security deposit: ₹2.72 crore
After Onkar Infotech purchased the property, DIAL acknowledged the ownership change, updated its security deposit details, and sought bank account information to continue rent payments. However, the dispute arose when Onkar declared that the lease deed was void due to lack of registration, reducing GMR’s status to that of month-to-month tenants.
In July 2024, Onkar issued a termination notice, refused to accept further rent, and initiated eviction proceedings.
GMR Group’s Defence
The GMR Group raised several legal arguments before the Delhi High Court, which were later brought up in appeal before the Supreme Court:
- Lease Validity – They claimed that although the lease was unregistered, correspondence and agreements had extended the lease up to 2028.
- Applicability of Delhi Land Reforms Act (DLR Act) – GMR argued that since the land was agricultural, eviction disputes fell under the DLR Act, which excludes the jurisdiction of civil courts.
- Ownership Records – They questioned Onkar Infotech’s status as a “bhumidhar” (landholder) in revenue records, challenging its legal capacity to seek eviction.
Delhi High Court’s Findings
In its order, the Delhi High Court rejected GMR’s defences and allowed eviction through summary judgment.
- Unregistered Lease: The Court held that an unregistered lease deed could not be relied upon to prove tenancy duration or lease extensions.
- DLR Act Inapplicability: Since the farmhouse was used solely for residential and non-agricultural purposes, the Court ruled that the DLR Act had no relevance.
- No Triable Issues: The Court concluded that the defendants (GMR entities) lacked a valid defence, making a trial unnecessary.
- Rejection of Plaints: GMR’s application to reject the eviction suit was also dismissed.
The High Court’s decision directly resulted in the eviction order against DIAL and GMR companies, which was subsequently challenged before the Supreme Court.
Key Legal Issues in the Case
The dispute raises several important legal questions that go beyond landlord-tenant conflicts:
- Registration of Lease Deeds
- Can an unregistered lease deed be relied upon to establish tenancy rights or extended duration?
- The Delhi High Court said no, but the Supreme Court will examine if surrounding communications and payments can constitute evidence of tenancy terms.
- Jurisdiction under Delhi Land Reforms Act (DLR Act)
- Does the agricultural nature of land automatically bring disputes under the DLR Act?
- Or does residential use override the agricultural classification?
- Rights of New Property Owners
- After the transfer of property ownership, can the new landlord invalidate an existing lease citing lack of registration?
- Or are tenants protected if rent is paid and accepted over time?
- Summary Judgment in Property Disputes
- Whether the High Court was correct in granting summary judgment without trial despite multiple contested issues.
Implications of the Supreme Court Stay
The stay order brings temporary relief to the *GMR CMD and DIAL, allowing them to continue residing at the farmhouse until the matter is fully heard. However, the case carries *significant implications for corporate leases, property law, and landlord-tenant relationships in India:
- Corporate Tenancies: Large corporations often lease residential or agricultural land for housing top executives. This case could set a precedent for how disputes over unregistered leases are handled.
- Land Reform Laws vs. Urban Reality: The applicability of agricultural land laws like the DLR Act to properties converted for residential use may be clarified.
- Property Transfers and Lease Rights: The rights of new owners vis-à-vis existing tenants will come under judicial scrutiny.
- Judicial Approach to Summary Judgments: The Supreme Court’s decision may redefine the scope of summary judgments in civil disputes where factual issues remain contested.
What Lies Ahead
The Supreme Court has now stayed the eviction and scheduled the next hearing for October 29, 2025. Until then, GMR Group retains possession of the property. The case will likely involve a detailed examination of lease law, property rights, and applicability of the DLR Act.
If the Court upholds the Delhi High Court’s order, it could mark a strict stance against unregistered leases and reinforce property owners’ rights. On the other hand, if it rules in favour of GMR, it may expand the scope of tenancy protections even where formal lease deeds are absent.
Conclusion
The Pushpanjali Farms eviction case is more than a high-profile property dispute involving a corporate giant; it touches upon fundamental legal principles of lease validity, jurisdiction, and property ownership. By staying the Delhi High Court’s order, the Supreme Court has signalled that the issues raised deserve deeper judicial scrutiny.
The final outcome will not only determine whether GMR CMD continues residing at the luxury farmhouse but will also shape the future contours of landlord-tenant law and corporate leasing practices in India.
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