In Brief
These consolidated appeals challenge the rejection of leave-to-defend applications filed by non-residential tenants in eviction proceedings under Section 14(1)(e) of the Delhi Rent Control Act, 1958. The appellants contend that Satyawati Sharma (2008), which extended Section 14(1)(e) to non-residential premises, should be reconsidered by a larger bench. The Supreme Court holds that Satyawati Sharma is not per incuriam, correctly applied the doctrine of temporal reasonableness to strike down unconstitutional discrimination, and that no grounds justify larger-bench reconsideration. The Court affirms the validity of extending bonafide need grounds to both residential and non-residential premises, noting legislative acceptance in the 1995 Delhi Rent Act.
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