INDRA KUMAR KARNANI versus ATUL CHANDRA PATITUNDI AND ANR.

INDRA KUMAR KARNANI versus ATUL CHANDRA PATITUNDI AND ANR.

Section 13(2) of the 1950 Act protects sub-tenants even in cases where sub-letting violates the agreement of lease, and landlord's consent is not required for sub-letting by tenant of first degree for sub-lessee to acquire tenant's rights.

Parties
Appellant: Indra Kumar Karnani; Respondent No. 2: Atul Chandra Patitundi; Respondent No. 1: Respondent No. 1
Jurisdiction
India
Judgment Date
10 March 1965
Procedural Posture
Civil Appeal / Appeal by Special Leave
Outcome
appeal dismissed
Legal Topics
Sub Letting, Sub Tenancy Rights, Landlord's Consent, Eviction, West Bengal Premises Rent Control

Case Brief

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Parties

Indra Kumar Karnani

Appellant

Atul Chandra Patitundi

Respondent No. 2

Respondent No. 1

Respondent No. 1

Procedural Posture

Civil Appeal / Appeal by Special Leave

  1. 1 Whether sub-tenants are protected under s. 13(2) of the West Bengal Premises Rent Control (Temporary Provisions) Act, 1950 when sub-letting is in violation of the lease agreement
  2. 2 Interpretation of s. 13(2) and s. 13(1) regarding necessity of landlord's consent for sub-letting
  3. 3 Whether rights of sub-tenants are saved under s. 13 even when eviction is sought due to sub-letting against lease conditions

Ratio Decidendi

Section 13(2) of the 1950 Act protects sub-tenants even in cases where sub-letting violates the agreement of lease, and landlord's consent is not required for sub-letting by tenant of first degree for sub-lessee to acquire tenant's rights.

Court Disposition

appeal dismissed

Orders

  • Suit of respondent No. 1 rightly decreed; appeal dismissed with costs.