The Supreme Court of India, in a judgment dated September 9, 2025, has held that a rent receipt serves as prima facie evidence of a landlord-tenant relationship under the Karnataka Rent Act, 1999. A bench comprising Justice J.K. Maheshwari and Justice Vijay Bishnoi ruled that once such a receipt is produced, the Rent Controller is justified in proceeding with an eviction case and is not required to halt proceedings to adjudicate on complex questions of title.
The Court set aside a judgment of the High Court of Karnataka, which had overturned an eviction order on the grounds that the landlord had not sufficiently proven his title and lineage. The Supreme Court restored the order of the Rent Controller, directing the tenant to vacate the premises.
Background of the Case
The dispute concerned property No. 7, 26th Cross, Cubon Pet, Bengaluru. The appellant, H.S. Puttashankara, filed an eviction petition against the respondent-tenant, Yashodamma, before the Court of Small Causes at Bangalore (the ‘Rent Controller’) under Section 27(2)(a), (e), (g), and (o) of the Karnataka Rent Act, 1999.
On September 1, 2017, the Rent Controller allowed the petition, establishing a landlord-tenant relationship and directing Yashodamma to “quit, vacate and deliver vacant possession” of the property within three months.
The respondent challenged this order before the High Court of Karnataka. On March 31, 2021, the High Court allowed the revision petition and set aside the eviction order. It noted that the appellant had failed to provide “positive documentary evidence” to prove his lineage to the original owner, Sri Banappa. The High Court was also influenced by the categorical denial from the respondent’s son, who stated that he had not signed the counter-foils of the rent receipts presented by the landlord. Aggrieved by this reversal, the appellant approached the Supreme Court.
Arguments of the Parties
The appellant-landlord contended that the property originally belonged to his great-grandfather, Sri Banappa. He claimed ownership through a release deed dated November 4, 2015, executed by other legal heirs. He further argued that the respondent’s mother, Mysore Lingamma, was the original tenant of his father, H.S. Shankarnarayana, a fact admitted in a previous eviction proceeding (HRC No. 1971/1980). Upon her death, Yashodamma was substituted as the legal heir and continued the tenancy.
The respondent-tenant denied the existence of any jural relationship of landlord and tenant. Her case was that the property belongs to Ankalappa Mutt and that Sri Banappa was merely one of its Trustees. She claimed to be a tenant under the Mutt and asserted that the appellant had no title to the property. She also stated that objections to the appellant’s claim of ownership based on the release deed were pending before revenue officials.
Court’s Analysis and Findings
The Supreme Court centered its analysis on the interpretation of Section 43 of the Karnataka Rent Act, 1999, which governs disputes over the landlord-tenant relationship. The Court observed that Section 43(1) permits the Rent Controller “to accept the document of lease or where there is no document of lease, a receipt of acknowledgement of payment of rent purported to be signed by the landlord as prima-facie evidence of relationship and proceed to hear the case.”
The judgment also referred to the definition of “landlord” under Section 3(e) of the Act, which includes any person “who for the time being is receiving or is entitled to receive, the rent of any premises.”
The bench found that the appellant had discharged his initial burden under Section 43 by producing original rent receipts issued to the respondent. Specifically, a receipt dated July 20, 2015, for rent collected for the period from February 1, 2013, to May 31, 2014, “prima-facie indicates that he stood as the landlord for the purpose of Section 3(e).”
The Supreme Court concluded that the Rent Controller was correct in proceeding with the hearing after this initial burden was met. It held that proceedings are to be stopped and parties referred to a civil court only when a lease is oral, the relationship is denied, and no rent receipt is produced, or if the court has reason to suspect the genuineness of the documents.
The Court found that the High Court had erred in its approach. The judgment stated, “The High Court in its own wisdom, misdirected itself in exercise of revisional jurisdiction in setting aside the order of the Rent Controller on the premise that jural relationship of landlord-tenant does not exist between the parties because the appellant-landlord wasn’t able to prove his lineage and relationship with Sri Banappa.”
Furthermore, the Supreme Court observed that the High Court should not have conducted a “fact-finding exercise” in its revisional jurisdiction. The judgment 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.”
Final Decision
Concluding that the High Court had not duly considered the mandate of Section 43 of the Act, the Supreme Court allowed the appeal. The final judgment dated March 31, 2021, passed by the High Court of Karnataka was set aside, and the eviction order passed by the Rent Controller on September 1, 2017, was restored.
