Supreme Court Restores Eviction Order and Holds Rent Receipts Are Prima-Facie Evidence of Tenancy

A bench of Justices J.K. Maheshwari and Vijay Bishnoi heard an appeal by a landlord challenging the Karnataka High Court's order that had set aside an eviction directed by the Rent Controller. The appeal arose from an eviction petition under Sections 27(2)(a), (e), (g) and (o) of the Karnataka Rent Act, 1999, where the core issue was the existence of a jural relationship of landlord and tenant and the ownership of the disputed premises.

The Court allowed the appeal, set aside the High Court's revisional order and restored the Rent Controller's eviction decree directing the respondent to vacate the premises. The Supreme Court held that once the landlord discharged the initial burden under Section 43 of the Karnataka Rent Act by producing rent receipts or receipts acknowledging payment of rent, the Rent Controller was justified in proceeding to hear the eviction on merits. The Court emphasised that the Rent Controller did not have jurisdiction to adjudicate rival title claims and that a revisional court should not undertake fresh fact-finding to overturn such an order. The Court, in its reasoning, observed: The Court further noted that the original rent receipt dated 20.07.2015 "prima-facie indicated that [the appellant] stood as the landlord" for the suit property and that the High Court erred in setting aside the Rent Controller's order by conducting a fact-finding exercise beyond the scope of revisional jurisdiction.

Background The dispute concerned property No. 7, 26th Cross, Cubbonpet, Bengaluru. The appellant-landlord claimed title by descent from his great-grandfather Sri Banappa and by a release deed dated 04.11.2015 allegedly transferring the property in his favour. The respondent denied the landlord-tenant relationship and contended that the property belonged to Ankalappa Mutt, with the respondent's mother having been a tenant. The Rent Controller, on evidence including rent receipts, concluded that a landlord-tenant relationship existed and allowed eviction. On revision, the High Court set aside that order, observing that the appellant had not proved lineage or ownership and noting denial of signatures on the rent receipts by the respondent’s son. The Supreme Court reviewed Section 43 of the Karnataka Rent Act, 1999 and Section 3(e), held that production of rent receipts constituted prima-facie evidence permitting continuation of eviction proceedings, and explained that only where the genuineness of such documents was contested or there was reason to suspect them should proceedings be stayed and parties referred to a competent civil court for declaration of title. The Court found that the High Court, in revisional jurisdiction, improperly reappraised evidence and engaged in fact-finding. Consequently, the appeal was allowed, the High Court's order was set aside and the Rent Controller's eviction order was restored; pending applications were dismissed.

Case Details: Case No.: 2025 INSC 1087 Case Title: H.S. Puttashankara v. Yashodamma Appearances: For the Petitioner(s): [Advocates not specified in the judgment] For the Respondent(s): [Advocates not specified in the judgment]