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Kumar Raj Krishna Prosad Lal Singh Deo vs Barabani Coal Concern Ltd. And Ors. on 20 July, 1934

Jagannath AIR (1976) SC 2355, has also ruled that in a suit for eviction by landlord, the tenant is estopped from questioning the title of the landlord because of Section 116 of the Act. The Judicial Committee in Kumar Krishna Prasad Lal Singha Deo v. Baraboni Coal Concern Ltd3, when had occasion to examine the contention based oil the words 'at the beginning of the tenancy' in Section 1 16 of the Evidence Act, pronounced that they do not give a round for a person already in possession of land becoming tenant of another, to 16 CRP NO.201 OF 2021 contend that there is no estoppel against his denying his subsequent lessor's title. Ever since, the accepted position is that Section 116 of the Evidence Act applies and estops even a person already in possession as tenant under one landlord from denying the title of his subsequent landlord when once he acknowledges him as his landlord by attornment or conduct. Therefore, a tenant of immovable property under landlord who becomes a tenant under another landlord by accepting him to be the owner who had derived title from the former landlord, cannot be permitted to deny the latter's title, even when he is sought to be evicted by the latter on a permitted ground.
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