R. VENKATASWAMI NAIDU AND ANOTHER vs NARASRAM NARAINDAS

The Supreme Court ruled that tenants who built structures in breach of a covenant not to build are still entitled to compensation under Section 3 and the right to purchase the land under Section 9 of the Madras City Tenants Protection Act, 1922. The Court clarified that the definition of 'tenant' in Section 3 includes all tenants, regardless of any covenants, as Section 12 protects tenant rights against contractual limitations. The High Court's interpretation that a breach of covenant negates compensation was rejected, affirming the tenants' rights under the Act.