INDRA KUMAR KARNANI vs ATUL CHANDRA PATITUNDI AND ANR.

The Supreme Court held that under Section 13(2) of the West Bengal Premises Rent Control (Temporary Provisions) Act, 1950, a sub-lessee acquires rights without the landlord's consent if the sub-letting is by a tenant of the first degree. However, if the sub-letting is by a tenant inferior to the first degree, consent from both the landlord and the superior tenant is required. The Court clarified that sub-tenants' rights are protected even if the landlord has initiated eviction proceedings under Section 12(1)(c), affirming the lower courts' decisions and dismissing the appeal.