Supreme Court: Tenant Who Took Possession Under Landlord’s Rent Deed Cannot Later Challenge Landlord’s Title
The Supreme Court has held that when a person enters into possession of a premises as tenant under a rent deed executed by the landlord, they cannot subsequently dispute the landlord’s ownership of that very property.
Facts of the Case
The dispute related to a shop that was let out in 1953. The original landlord executed a rent deed in favour of the tenants’ predecessors, who paid rent continuously to him and thereafter to his heirs. The landlord’s successor claimed ownership by will and sought eviction. The tenants challenged the landlord’s title, alleging that the original landlord had no valid title and that the will was forged. The lower courts rejected the landlord’s claim; however, the Supreme Court intervened.
Holding & Reasoning
The Court found that the original landlord’s title was clearly established through a relinquishment deed and long-standing rent payments.
The tenants, by entering into the rent deed and paying rent over decades, were in a tenant-landlord relationship and thereby estopped from disputing the landlord’s ownership.
The Court emphasised: “The tenant having come into possession of the tenanted premises by a rent deed executed by the earlier landlord cannot turn around and challenge his ownership.”
The judgment clarifies that a tenancy relationship based on the landlord’s title precludes the tenant from later attacking that title in eviction proceedings.
Significance
This decision reinforces the principle that long-term tenants cannot use prolonged occupancy or rent payments as a ground to challenge the landlord’s ownership when their entry into possession was under a rent deed. It strengthens landlords’ rights in eviction law, especially where the tenancy was formal and rent was consistently paid.
