M.M. QUASIM vs MANOHAR LAL SHARMA & ORS.

The Supreme Court held that under Section 11(1)(c) and (d) of the Bihar Buildings (Lease, Rent and Eviction) Control Act, 1947, a landlord can maintain eviction proceedings for bona fide personal requirement despite a partition of property if the tenant has defaulted in rent payment. The Court found that the appellant's claim of not being a defaulter was unsubstantiated as he failed to provide adequate proof of payment. The appeal was dismissed, affirming the lower courts' decisions on both grounds of eviction.