V. SANJEEVARAYA MUDALIAR vs N.A. RAGHAVACHARY

The Supreme Court held that a tenant of a vacant site in the backyard of a residential house is considered a tenant of land under Section 2(2) of the Madras City Tenant’s Protection Act, 1921. The Court ruled that despite the tenant's breach of a stipulation against erecting permanent structures, he is still entitled to protections under Sections 3 and 9 of the Act, as the stipulation was made in a registered deed. The Court clarified that only stipulations made orally or in unregistered writings are not protected, thus affirming the trial court's decree for eviction.