VidhiSangh

Supreme Court of India · 17/06/2020

SIRI CHAND (DECEASED) THR. LRS. versus SURINDER SINGH

[2020] 5 S.C.R. 265 · 2020 INSC 431

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Summary

A rent note creating an unspecified-duration monthly tenancy did not require registration merely because it promised a 10% annual rent increase. Read cumulatively, the monthly payment and termination terms showed no guaranteed tenancy exceeding one year; the increase was contingent on continuation. The appellate court also failed to find that rent and house-tax defaults were cured. The Rent Controller’s eviction decree was restored.

Issues

  1. Whether the annual rent-increase clause made the rent note compulsorily registrable.
  2. Whether the eviction decree could be reversed without findings addressing the tenant’s defaults.

Provisions considered

Held

Result

Appeal allowed; Rent Controller’s judgment and eviction decree restored. No costs.

Judgment PDF: Supreme Court of India, [2020] 5 S.C.R. 265.