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Issues Involved:
1. Constitutional validity of the East Punjab Urban Rent Restriction (Amendment) Act, 1956. 2. Classification of buildings into residential and non-residential. 3. Bona fide requirement of landlords for eviction of tenants from non-residential premises. Summary: 1. Constitutional Validity of the Amendment: The East Punjab Urban Rent Restriction Act, 1949, initially allowed landlords to evict tenants from non-residential buildings on the grounds of bona fide requirement for personal use. However, the East Punjab Urban Rent Restriction (Amendment) Act, 1956, removed this right. The appellant challenged the constitutional validity of this amendment, arguing that it violated Article 14 of the Constitution of India. The High Court dismissed the writ petition under Article 226 of the Constitution, leading to this appeal. 2. Classification of Buildings: The appellant contended that the classification of buildings into residential and non-residential by the amendment had no reasonable nexus with the object sought to be achieved by the Act. The Supreme Court reiterated that for a classification to be permissible under Article 14, it must satisfy two conditions: (i) it must be founded on an intelligible differential, and (ii) the differential must have a rational relation to the object sought to be achieved by the statute. 3. Bona Fide Requirement of Landlords: The Court examined the statement of objects and reasons for both the original Act and the amendment. The primary purpose of the Act was to protect tenants against mala fide eviction attempts by landlords. The amendment aimed to align the Punjab Act with the Delhi Ajmer Rent Control Act, which did not allow eviction from non-residential premises on the grounds of personal use. The Court found that the amendment created a classification that had no nexus with the object of the Act and was patently harsh and unjust for landlords. The Court cited previous judgments, including Rattan Arya vs. State of Tamil Nadu and Gian Devi Anand vs. Jeevan Kumar & Ors., to support its view that bona fide need for personal use should be a legitimate ground for eviction for both residential and non-residential premises. Judgment: The Supreme Court held that the provisions of the amendment were violative of Article 14 of the Constitution and were liable to be struck down. The appeal was allowed, the impugned judgment of the High Court was set aside, and the original provisions of the Act were restored. Consequently, landlords could seek eviction of tenants from non-residential buildings on the grounds of bona fide requirement for personal use. The parties were to bear their own costs.
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