SAFALI ROY CHOUDHURY & ORS. vs AMARENDRA KUMAR DUTTA

The Supreme Court held that the doctrine of lis pendens does not apply in this case, as it prevents parties from alienating property in dispute during litigation. The Court emphasized that Section 40 of the West Bengal Premises Tenancy Act, 1956 allows for the continuation of proceedings initiated under the repealed West Bengal Premises Rent Control (Temporary Provisions) Act, 1950. The Court ruled that the sub-tenant's rights under Section 16 of the 1956 Act were valid, and thus the tenant's eviction application was dismissed, affirming the sub-tenant's status as a direct tenant under the landlord.