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N.M. Nayak vs Chhotalal Hari Ram And Ors. on 1 February, 1967

The amendment was introduced into the Act by the Maharashtra Act No. 17 of 1968 with retrospective effect as from 12 May 1948. The amendment was brought into existence as a result of the decision of the Bombay High Court in Nayak's case (supra). The High Court held in that case that a person seeking to claim protection by the provisions contained in the notification issued under the proviso to section 15 (1 ) of the Act must establish that his transferor was a lessee of the premises transferred or assigned. The decision was to the effect that the only persons who were entitled to transfer or assign the interest of the premises were to satisfy the character of a lessee as defined in section 105 of the Transfer of Property Act. The assignee of a lessee was held not to be a lessee as defined by the Transfer of Property Act. In this context, the explanation to section 15(1) of the Act as well as sub-clause (aa) in clause (ii) of section 5 of the Act were introduced to confer protection on the successive transfer by original lessees in regard to leases or class of leases notified under the proviso to section 15(1) of the Act.
Bombay High Court Cites 22 - Cited by 5 - Full Document
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