In Brief
A landlord sought eviction of commercial tenants from a ground floor shop in Vadodara under the Bombay Rent Control Act. The original tenant had failed to pay rent for 22 months (1974–1976). After his death, his heirs and an unlawfully inducted third party remained in possession. The trial court ordered eviction on three grounds: arrears exceeding six months, non-succession of heirs, and sub-letting. The appellate courts reversed this, finding the tenancy was annual (not monthly) and protected under Section 12(3)(b). The Supreme Court restored the eviction order, holding the tenancy was monthly (evidenced by monthly receipts), the heirs did not actively work in the shop, and an unauthorized worker constituted sub-letting.
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