Punjab & Haryana High Court, Chandigarh
CitationAIR 1968 SC 1165
CourtSupreme Court of India
Date12 December 1967
Year1968
BenchK. Subba Rao, J.M. Shelat, V. Ramaswami JJ.
Acts/ArticlesTransfer of Property Act Sections 106, 111, 116
CategoryProperty & Land Law

Key Principle Established

A tenant who holds over after expiry of lease period becomes a tenant-at-sufferance. The landlord can evict such tenant by giving reasonable notice. Tenancy rights are governed by the terms of the lease.

Brief Facts

A tenant continued in possession after the expiry of the lease period. The landlord sought eviction.

Ratio Decidendi

The Court held that a tenant who holds over after lease expiry becomes a tenant-at-sufferance if the landlord does not consent to the continuation. The landlord’s acceptance of rent after lease expiry may create a new tenancy (tenancy by holding over under Section 116 TPA), but this is rebuttable. The landlord can evict by giving notice as prescribed under Section 106.

Impact & Significance

This is a foundational authority on holding-over tenancy and the rights of landlords and tenants after lease expiry.

Tags & Related Topics

Property & Land Law Transfer of Property Act Sections 106 111 116
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Disclaimer

This judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).

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