M. C. CHOCKALINGAM & ORS. vs V. MANICKAVASAGAM & ORS.

The Supreme Court held that a non-statutory tenant cannot claim 'lawful possession' after the expiry of a lease, as per the Madras Cinemas (Regulations) Act, 1955, specifically Sections 5(1) and 5(7). The Court found that the High Court erred in interpreting Rule 13 of the Madras Cinemas (Regulations) Rules, 1957, which led to the erroneous conclusion that the respondent was in lawful possession post-lease. The appeal was allowed, and the High Court's decision was set aside, reinforcing the principle that possession must be lawful and not merely based on an expired lease.