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Shiv Sarup Gupta vs Dr. Mahesh Chand Gupta on 30 July, 1999

In Adil Jamshed Frenchman v. Sardur Dastur Schools Trust [(2005) 2 SCC 476] the Apex Court reiterated that, as laid down in Shiv Samp Gupta v. Dr. Mahesh Chand Gupta [(1999) 6 SCC 222] a bona fide requirement must be an outcome of a sincere and honest desire in contradistinction with a mere pretext for evicting the tenant on the part of the landlord claiming to occupy the premises for himself or for any member of the family which R.C.Rev. No.211 of 2019 -11- would entitle the landlord to seek ejectment of the tenant. The question to be asked by a judge of facts by placing himself in the place of the landlord is whether in the given facts proved by the material on record the need to occupy the premises can be said to be natural, real, sincere and honest. The concept of bona fide need or genuine requirement needs a practical approach instructed by the realities of life.
Supreme Court of India Cites 12 - Cited by 974 - R C Lahoti - Full Document

Jerry Joseph vs Selvaraj on 2 April, 2002

12. The said finding of the Rent Control Court was reversed by the Appellate Authority in its judgment in R.C.A.No.7 of 2018 dated 31.01.2019. The Appellate Authority noticed that the son of the landlord, who was examined as PW2, has supported the case of the landlord, who was examined as PW1, for an order of eviction under Section 11(3) of the Act. After analysing the pleadings and evidence on record, the Appellate Authority found that the oral testimonies of PWs 1 and 2 are sufficient to establish the need projected in the Rent Control Petition to seek an order of eviction under Section 11(3) of the Act. The Appellate Authority noticed that, while considering the bona fide need of the landlord, the Rent Control Court went to the extent of analysing the suitability of the building for the purpose of starting a mobile phone business by PW2. Relying on the decision of this Court in Jerry Joseph v. Selvaraj [2002 (2) KLT 129], wherein it was held that the tenant cannot dictate the landlord regarding his need or choice of the building, the Appellate Authority R.C.Rev. No.211 of 2019 -14- found that the reasoning of the Rent Control Court to doubt the bona fides of the need projected in the Rent Control Petition cannot be sustained.

Ram Narain Arora vs Asha Rani & Ors on 31 August, 1998

In the said decision, the Apex Court relied on the law laid down in Ram Narain Arora v. Asha Rani [(1999) 1 SCC 141], wherein it was held that the question whether the landlord has any other reasonably suitable residential accommodation is a question which is intermixed with the question regarding bona fide requirement. Whether the landlord has any other reasonably suitable residential accommodation is a defence for the tenant. Whether the other accommodation is more suitable than the suit premises would not solely depend upon pleadings and non-disclosure by the landlord. The landlord having another accommodation would not be fatal to the eviction proceedings if both the parties understood the case and placed materials before the court and case of neither party was prejudiced. On the facts of the case on hand, the Apex Court found that, even though the landlord has not mentioned about the other two premises, the material in respect of the other two premises was placed before the Rent Controller as well as before the High Court, thus no prejudice has been caused, and the parties have squarely dealt with this question.
Supreme Court of India Cites 5 - Cited by 177 - S R Babu - Full Document

Vineethan vs Fathima on 17 October, 2015

Vide: Narayanan Nair v. Pachumma [1980 KLT 430], Prasannan v. Haris [2005 (2) KLT 365], Vineethan v. Fathima and others [2016 (1) KHC 631]. In view of the legal position well settled by the aforesaid decisions, the landlord is not required to plead or prove other sources of income of the tenant. That apart, income is a fact which remains exclusively in the knowledge of each person only and another person cannot adduce evidence to prove income. Merely on the reason that the landlord has stated that the tenant has other sources of income and he is not mainly depending upon the income from the business carried on in the tenanted premises, for his livelihood and he failed to prove so, the tenant cannot escape from the burden of proof cast on him under the first limb of the second proviso to Section 11(3) of the Act. Where the statutory provision itself explicitly imposes the burden of proof on a party to the lis, there cannot be any variation whatever be the pleadings of the other party in that respect. The second proviso to Section 11(3) is an exception to the principal provision, granting R.C.Rev. No.211 of 2019 -21- protection to the tenant. When the second proviso itself imposes the burden of proof on the tenant, the question whether the landlord has pleaded or proved the facts constituting the said proviso is insignificant and irrelevant. Even if the landlord pleaded so, the burden of proof will not be shifted to him. Since the second proviso to Section 11(3) is an exception to the principal provision, which would dis-entitle the landlord to get the order of eviction under Section 11(3), the burden of proof, under the said proviso is always on the tenant and unless the burden of proof under the second proviso is discharged satisfactorily, the tenant is not entitled to get protection under the said proviso to Section 11(3) of the Act.

M/S Bharat Sales Ltd vs Life Insurance Corporation Of India on 5 February, 1998

In Bharath Sales Ltd. v. Life Insurance Corporation of India [(1998) 3 SCC 1] the Apex Court held that sub tenancy or subletting comes into existence when the tenant gives up possession of the tenanted accommodation, wholly or in part, and puts another person in exclusive possession thereof. This arrangement comes about obviously under a mutual agreement or understanding between the tenant and the person to whom the possession is so delivered. In this process, the landlord is kept out of the scene. Rather, the scene is enacted behind the back of the landlord, concealing the overt acts and transferring possession clandestinely to a person who is an utter stranger to the landlord, in the sense that the landlord had not let out the premises to that person nor had he allowed or consented to his entering into possession over the demised property. It is the actual, physical and exclusive possession of that person, instead of the tenant, which ultimately reveals to the landlord that the tenant to whom the property was let out has put some other person into possession of that property. In such a situation, it would be difficult for the landlord to prove, by R.C.Rev. No.211 of 2019 -25- direct evidence, the contract or agreement or understanding between the tenant and the sub tenant. It would also be difficult for the landlord to prove, by direct evidence, that the person to whom the property had been sublet had paid monetary consideration to the tenant. Payment of rent, undoubtedly, is an essential element of lease or sub lease. It may be paid in cash or in kind or may have been paid or promised to be paid. It may have been paid in lump-sum in advance covering the period for which the premises is let out or sublet or it may have been paid or promised to be paid periodically. Since payment of rent or monetary consideration may have been made secretly, the law does not require such payment to be proved by affirmative evidence and the court is permitted to draw its own inference upon the facts of the case proved at the trial, including the delivery of exclusive possession to infer that the premises were sublet.
Supreme Court of India Cites 8 - Cited by 235 - S S Ahmad - Full Document

Unni Vacco vs Thankamma Gregory on 3 February, 2003

In Unni Vacco v. Thankamma Gregory [2003 (2) KLT 459] a Division Bench of this Court held that, it is true that with regard to the question of sub-lease, there should be an exclusive possession by the alleged sub-lessee. R.C.Rev. No.211 of 2019 -26- But as stated in many cases, the transaction is between the lessee and sub-lessee. When a person other than the tenant is found to be in the building, the burden is on the tenant to show that there is no sub-lease or transfer of possession. On the facts of the case on hand, the Division Bench found that the tenant has not discharged the burden. Both the courts found that the sub-lease is proved. The tenant, even though had tried to argue on the basis of the licence, the mere fact that the licence is in the name of the tenant cannot ignore the possibility of another person being in possession. The Commissioner has visited the property and he has filed a report. His evidence is relevant. There is nothing wrong in accepting the report of the Commissioner and on the basis of it, the other evidence adduced in the case, one can come to the conclusion that the tenant has not been successful in establishing that respondents 2, 3 and 4 are not in exclusive possession. The Division Bench noticed that the evidence of RW1, the Secretary of Kerala High Court Bar Association also shows that the second respondent is conducting a hotel in his own name.
Kerala High Court Cites 6 - Cited by 7 - K K Denesan - Full Document
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