D.H. MANIAR & ORS. vs WAMAN LAXMAN KUDAV

The Supreme Court held that for a licensee to gain protection under Section 15A of the Bombay Rent Act, they must be in occupation as a licensee under a subsisting agreement on February 1, 1973. The Court clarified that if the licensee does not meet this criterion, they are not entitled to the protections afforded by the amendment. The High Court's ruling that the license was not terminated was overturned, affirming that the respondent was not a licensee under a subsisting agreement as of the relevant date, thus denying them tenant status under the amended Act.