The Supreme Court stepped in to correct a long-running rent dispute, holding that tenants who have acknowledged a landlord for decades cannot later question that landlord’s title. In Jyoti Sharma v. Vishnu Goyal, the Court accepted the validity of a probated Will, affirmed the landlord’s bona fide need to expand her family sweets business, and ordered eviction along with decades-old rent arrears. The ruling brings clarity to an area where trial courts and appellate courts had taken inconsistent views, strengthening landlords’ rights under rent control laws while giving tenants a reasonable window to vacate.

Legal Issue

Whether a tenant can dispute the ownership of the landlord after decades of tenancy, and whether eviction can be granted on the grounds of bona fide need and rent default where the landlord claims title through a probated Will.

Brief Facts

The dispute involved a shop room rented out in 1953 to the father of the respondents by one Ramji Das. After Ramji Das’s death in 1999, his daughter-in-law Jyoti Sharma (the plaintiff) claimed ownership under a Will dated 12.05.1999. She sought eviction of the tenants on the grounds of bona fide need and rent default. The defendants denied her ownership, alleging that the Will was fraudulent and that Ramji Das had no title since the property originally belonged to his uncle, Sua Lal.

The trial court dismissed the suit, doubting the Will’s validity. The first appellate court initially remanded certain issues, and after subsequent appeals, the findings of the trial court were affirmed by the High Court.

Court’s Reasoning

1. The Supreme Court held that the tenant, having entered possession under a rent deed executed by Ramji Das and having paid rent to him for decades, could not later challenge his ownership.
2. The Court noted that a relinquishment deed executed by Sua Lal in 1953 vested title in Ramji Das, proving his ownership.
3. The Will bequeathing the shop to Jyoti Sharma had since been probated by a competent court in 2018. Hence, her ownership could not be questioned.
4. The Court emphasized that in eviction suits, ownership need not be proved as strictly as in declaratory suits.
5. It found the lower courts’ findings perverse and unsupported by the evidence.
6. On the issue of bona fide need, the Court accepted that Jyoti Sharma intended to expand her family’s sweets and savouries business and that her need was genuine.

Judgment

The Supreme Court set aside the judgments of the trial court, first appellate court, and the High Court. The suit was decreed in favour of Jyoti Sharma. The Court ordered recovery of rent arrears from January 2000 until possession is handed over and directed eviction on the grounds of rent default and bona fide need.

Considering the long tenancy, the respondents (tenants) were granted six months to vacate, subject to filing an undertaking before the trial court to pay arrears within one month and deliver vacant possession within six months. Failure to file such undertaking would entitle the plaintiff to seek summary eviction.

Subsequent Development

The judgment reinforces the principle that tenants cannot challenge a landlord’s title after acknowledging tenancy for decades and clarifies that a bona fide requirement for business expansion constitutes valid grounds for eviction under rent control laws.

To Read the full judgment, click here

Case Title: Jyoti Sharma v. Vishnu Goyal & Anr.

Neutral Citation: SLP (C) No. 29500 of 2024

Court: Supreme Court of India

Bench: Justice J.K. Maheshwari and Justice K. Vinod Chandran