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Issues Involved:
The issue involves the interpretation of Section 14(1)(e) of the Delhi Rent Control Act, 1958, regarding eviction based on bona fide requirement of the landlord and the availability of alternative accommodation. Judgment Summary: Issue 1: The appeal challenged the High Court's reversal of the Rent Controller's order directing eviction under Section 14(1)(e). The Supreme Court held that the High Court erred in interfering without valid grounds, emphasizing the landlord's bona fide need and lack of alternative accommodation. The Court highlighted that the High Court's revisional power should not override the Rent Controller's decision based on legal principles and objective assessment. Issue 2: The appellant, a widow, sought eviction for personal use, as she was staying with a family friend without legal right to the premises. The Court rejected the High Court's reasoning based on the appellant's age and need for care, asserting the landlord's freedom to decide residential requirements. It emphasized the landlord's right to beneficial property enjoyment and reversed the High Court's finding, reinstating the Rent Controller's decision on the appellant's bona fide requirement. Issue 3: The appellant relied on a Single Judge's observations misinterpreting the legal test for alternative accommodation under Section 14(1)(e). The Supreme Court clarified that the availability of alternative accommodation should consider the landlord's legal right, not just mere availability. It overruled the High Court's decision for not aligning with legal principles established in previous cases. Issue 4: The Court emphasized that the landlord's bona fide requirement under Section 14(1)(e) should not be denied solely based on temporary stay arrangements, reiterating the importance of legal right to alternative accommodation. The appellant's claim was upheld as genuine, and the High Court's decision disallowing the claim was deemed unsupported. Issue 5: The appeal was allowed, costs were awarded, and the High Court's decision was set aside. The Rent Controller's order for eviction under Section 14(1)(e) was restored, granting the respondent four months to vacate the premises upon filing the necessary undertaking within four weeks. This judgment clarifies the legal principles governing eviction under Section 14(1)(e) of the Delhi Rent Control Act, emphasizing the landlord's bona fide requirement and legal right to alternative accommodation in determining eviction proceedings.
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