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Nagubai Ammal & Others vs B. Shama Rao & Others on 26 April, 1956

The next question is whether the tenants by non-payment of rent for one or two months can be said to have committed 'wilful default'. It was not disputed at the hearing that simply non-payment of rent by the tenant is not enough; there should be a 'wilful default' so as to make out a ground for eviction under the Act. The expression wilful default as employed in Section 10(2) of the Act came up for the consideration of this Court in S.Sundaram Pillai etc. etc. Vs. V.R. Pattabiraman etc.etc. (1985) 1 SCC 591. After dealing with all the relevant aspects touching the expression and the setting in which the expression has been employed in the Act, this Court held "Thus, a consensus of the meaning of the words "wilful default" appears to indicate that default in order to be wilful must be intentional, deliberate, calculated and conscious, with full knowledge of legal consequences flowing therefrom. Taking for instance a case where a tenant commits default after default despite oral demands or reminders and fails to pay the rent without any just or lawful cause, it cannot be said that he is not guilty of wilful default because such a course of conduct manifestly amounts to wilful default as contemplated either by the Act or by other Acts referred to above."
Supreme Court of India Cites 9 - Cited by 565 - S J Imam - Full Document

D.C. Oswal vs V.K.Subbiah And Ors on 12 November, 1991

The course of conduct prevailing between the parties for collecting rent is one of the relevant factors. If the landlord has been accepting payments made in lumpsum for quite a long time and in a situation where the landlord had consented to collect rent for two to three months at a time, non-payment of rent for some little time cannot constitute wilful default, is the view taken by this Court in Premchand Ranka Vs. A. Vasanthraj Khatod & Ors. (1992) 1 SCC 369 and D.C. Oswal Vs. V.K. Subbiah and Ors. (1992) 1 SCC 370. In the case before us we have the landlord's own statement that rent was being collected from the tenants by the landlords once in two months. Then there is either the absence of notice or a doubt about the service of notice on the tenant from the landlords demanding payment of rent. Additionally there are the facts that a sister of landlord was pressurizing the tenants to make apportionment of rent in her favour and the Municipal Corporation was holding out threat of eviction if arrears as to premises were not directly paid to it. These two events could have reasonably caused a wavering in the mind of tenants to whom to pay. In this state of the facts non-payment of rent for one month in respect of one of the premises and for two months in respect of the other cannot be enough to brand the tenants as 'wilful defaulters'.
Supreme Court of India Cites 2 - Cited by 132 - R B Misra - Full Document
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