MST. SURAYYA BEGUM, ETC. vs MOHD. USMAN AND ORS., ETC.

The Supreme Court held that the principle of representation allows a person not impleaded in eviction proceedings to contest the execution of a decree if their tenancy rights are independent. The Court clarified that under Section 11, Explanation VI of the Code of Civil Procedure, 1908, a named party can represent the interests of others not named in the proceedings. The appeal was allowed, affirming that the decree against the original tenants does not bind those not impleaded, thereby protecting their rights to tenancy under the Delhi Rent Control Act, 1958.