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Case Overview

Case Name : Jyoti Sharma vs. Vishnu Goyal

A Bench of Justice JK Maheshwari and Justice K. Vinod Chandran of the Supreme Court of India delivered a landmark judgment in a dispute concerning ownership and tenancy rights . The litigation originated in 1953 between the successors of the original landlord Ramji Das and tenant Sua Lal . The plaintiff, daughter-in-law of Ramji Das, sought eviction of tenants on the basis of a Will dated May 12, 1999 claiming bona fide need to expand her family’s sweets and savouries business . The tenants challenged her title, alleging that the Will was fabricated and that Ramji Das had no ownership rights .

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Key Aspects

The Court examined long-standing possession, payment of rent and ownership documents to resolve the dispute . It highlighted that once tenancy is accepted, ownership cannot be questioned later .

• The tenants’ predecessors had rented the property from Ramji Das and paid rent since 1953 .
• They continued rent payments to his son after his death, acknowledging his ownership .
• The tenants later disputed ownership, claiming the property belonged to Sua Lal, uncle of Ramji Das .
• Exhibit P-18, a 1953 relinquishment deed, proved Ramji Das’s ownership conclusively .

Legal Insights

The Court reaffirmed key principles of tenancy and ownership under Indian law .

• Section 116, Indian Evidence Act, 1872 – A tenant who has entered possession under a landlord is estopped from denying the landlord’s title during the tenancy .
• Section 14(1)(e), Delhi Rent Control Act, 1958 – Allows eviction for bona fide need of the landlord’s premises (principle applied similarly) .
• The Probate Order of 2018 validated the Will of Ramji Das, granting the plaintiff lawful ownership .
• Suspicion over exclusion of the wife in the Will was held not a valid legal ground for disbelief .

Court’s Verdict

The Supreme Court of India set aside concurrent findings of the lower courts ruling in favour of the landlord’s successor. It decreed eviction of tenants and ordered recovery of rent arrears from January 2000 until possession is handed over . The tenants were granted six months’ time to vacate upon filing an undertaking to clear dues within one month . The Court reaffirmed that a tenant cannot dispute landlord ownership later after accepting tenancy and paying rent .

Source – Supreme Court of India 

Read also – Indian Evidence Act, 1872 

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