S. SUNDARAM PILLAI, ETC. vs V.R. PATTABIRAMAN ETC.

The Supreme Court interpreted 'wilful default' under Section 10(2)(i) of the Tamil Nadu Buildings (Lease and Rent Control) Act, 1960, clarifying that a tenant's non-payment of rent after two months' notice does not automatically constitute wilful default if the circumstances warrant a different conclusion. The Court held that the Controller must assess the specifics of each case rather than rely solely on the Explanation added by Act 23 of 1973. The appeals were allowed, overturning the Madras High Court's eviction orders against the tenants.