Court’s Decision
The Supreme Court allowed the appeal filed by the landlord, setting aside the Karnataka High Court’s order that had reversed an eviction decree. The Court held that under Section 43 of the Karnataka Rent Act, 1999, once rent receipts are produced, they serve as prima facie evidence of the landlord-tenant relationship, and the Rent Controller is justified in proceeding with eviction. The High Court, while exercising revisional jurisdiction, had exceeded its scope by conducting a fact-finding exercise on ownership and lineage, which was impermissible. The eviction order of the Rent Controller was accordingly restored.
Facts
The dispute involved a property at 26th Cross, Cubbonpet, Bengaluru. The appellant claimed ownership of the property through a release deed executed in his favour in 2015 by his relatives, who were descendants of the original owner, Sri Banappa. He argued that the respondent’s mother, Mysore Lingamma, was a tenant in the same premises and had admitted in earlier eviction proceedings (HRC No. 1971/1980) that rent was paid to the appellant’s father, thereby confirming the landlord-tenant relationship. After Lingamma’s death, her daughter (the present respondent) continued as a tenant.
The Rent Controller, based on rent receipts issued by the appellant in 2015 acknowledging payments for 2013–2014, concluded that the landlord-tenant relationship existed and directed eviction. The High Court, however, allowed a revision petition in 2021, holding that the appellant had failed to prove his lineage and ownership, and that the respondent’s son had denied signing the rent receipts. The landlord appealed to the Supreme Court.
Issues
- Whether production of rent receipts is sufficient prima facie proof of landlord-tenant relationship under Section 43 of the Karnataka Rent Act, 1999.
- Whether the High Court, in its revisional jurisdiction, could reappreciate evidence and examine disputed questions of ownership and title.
- Whether denial of signatures on rent receipts by the respondent’s son could nullify the finding of landlord-tenant relationship.
Petitioner’s Arguments
The landlord argued that the respondent’s mother had already admitted the tenancy relationship in earlier eviction proceedings, and that the rent receipts issued in 2015 clearly established his status as landlord. He submitted that under Section 43, such receipts are sufficient to discharge the initial burden, after which the Rent Controller was bound to proceed.
It was contended that the High Court misdirected itself by delving into issues of title and ownership, which are beyond the jurisdiction of Rent Control proceedings. Revisional powers under the Karnataka Rent Act are narrow and cannot be used to reappreciate facts.
Respondent’s Arguments
The respondent denied the existence of a landlord-tenant relationship and claimed tenancy under Ankalappa Mutt, asserting that the appellant had no ownership rights. It was argued that Sri Banappa, whom the appellant traced lineage to, was merely a trustee of the Mutt, and therefore no title could flow to the appellant.
Further, the respondent highlighted that the signatures on the rent receipts were denied by her son, and thus their authenticity was doubtful. The High Court rightly found that the appellant had not proved his lineage or ownership, and therefore the eviction order was unsustainable.
Analysis of the Law
The Court analysed Section 43 of the Karnataka Rent Act, 1999, which provides that in cases where landlord-tenant relationship is denied, production of a lease document or rent receipts signed by the landlord is sufficient prima facie proof. If such documents exist, the Rent Controller must proceed with the case. Only when no such documents exist, or their genuineness is doubtful, should the matter be referred to a civil court for adjudication of title.
The Court emphasised that landlord under Section 3(e) includes not only the owner but also any person entitled to receive rent, including trustees or persons collecting rent on behalf of others. Thus, ownership disputes are irrelevant for determining tenancy in rent control proceedings.
Precedent Analysis
- Shanti Sharma v. Ved Prabha (1987) 4 SCC 193 – Clarified that landlord need not be the absolute owner; entitlement to receive rent is sufficient. Applied here to hold that the appellant qualified as landlord.
- V. Dhanapal Chettiar v. Yesodai Ammal (1979) 4 SCC 214 – Stated that Rent Control legislation is primarily concerned with landlord-tenant relationship, not title disputes. Relied on here to restrict High Court’s scope.
- Hindustan Petroleum Corp. Ltd. v. Dilbahar Singh (2014) 9 SCC 78 – Held that revisional jurisdiction cannot involve reappreciation of evidence; applied to fault the High Court’s fact-finding exercise.
These precedents guided the Court in reaffirming the Rent Controller’s approach and limiting the High Court’s intervention.
Court’s Reasoning
The Supreme Court observed that the appellant had produced original rent receipts showing payment by the respondent, which discharged the burden under Section 43. The High Court’s insistence on proof of lineage and ownership was misplaced, since ownership disputes are irrelevant in eviction proceedings.
The Court noted: “The High Court, in reaching a conclusion contrary to the Rent Controller, conducted a fact-finding exercise, which as per settled law ought to have been avoided in revisional jurisdiction.”
It clarified that denial of signatures by the respondent’s son did not erase the evidentiary value of the receipts, especially when earlier proceedings had already established tenancy of the respondent’s mother.
Conclusion
The appeal was allowed. The Supreme Court set aside the High Court’s order and restored the Rent Controller’s eviction decree. Pending applications were dismissed.
The Court reaffirmed that rent receipts are prima facie proof of tenancy and that High Courts cannot exceed revisional limits by adjudicating ownership disputes under Rent Acts.
Implications
This ruling reinforces the principle that Rent Control proceedings focus solely on the landlord-tenant relationship, not ownership disputes. It protects landlords from being denied eviction merely because of disputes over lineage or title.
It also curtails judicial overreach in revision, reminding High Courts that their role is supervisory, not appellate, and they cannot substitute their own fact-finding for that of the Rent Controller.
FAQs
Q1. Do landlords need to prove ownership in eviction cases under the Karnataka Rent Act?
No. The Act requires proof of entitlement to receive rent, not ownership. Rent receipts suffice as prima facie evidence.
Q2. Can High Courts reappreciate evidence in rent control revisions?
No. Revisional jurisdiction is limited; fact-finding or title adjudication is beyond its scope.
Q3. What documents establish landlord-tenant relationship under Section 43 of the Rent Act?
Lease agreements or rent receipts signed by the landlord are sufficient prima facie proof.
