Recently, in the matter of Jyoti Sharma v. Vishnu Goyal, the Hon’ble Supreme Court of India delivered a significant ruling in a long-pending landlord–tenant dispute. The dispute traces back to a tenancy created in 1953 and culminates in a decree of eviction on grounds of rent default and bona fide requirement, with the Supreme Court setting aside concurrent findings of the trial court, first appellate court, and High Court. In doing so, the Court clarified two critical legal principles: the standard of ownership proof required in eviction suits and the scope of tenant estoppel.

The tenants disputed the title of the original landlord, despite having taken possession under a rent deed executed by him in favor of their father. While rejecting this challenge, the Court reaffirmed that the burden of proving ownership in eviction proceedings is not equivalent to that in a title-declaration suit. In this regard, it observed:

“9…It is trite that in a suit for eviction, the proof of ownership of the tenanted premises is not to be strictly looked at as in a suit for declaration of title.”

Further, drawing on the doctrine of tenant estoppel, the Court observed as under:

“10….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. It is also an admitted fact that from 1953, the predecessor of the defendants and the defendants, after their father’s death had been paying rent to the said Ramji Das. The dispute regarding the title of Ramji Das could not have been raised by the tenant who had come into the premises by virtue of a deed executed by Ramji Das to whom, for more than half a century, the tenants were also paying rent.”

The aforesaid observations serve as a clear affirmation on the threshold of scrutiny of title in eviction suits and the bar against tenants disputing the landlord’s title.