STATE OF MADHYA PRADESH AND ORS. vs KRISHNARAO SHINDE AND ORS.

The Supreme Court held that the Gwalior Dairy Limited was a 'Government lessee' under Section 181 of the M.P. Land Revenue Code, 1959, and thus subject to eviction proceedings under Section 182(2)(i) for failure to pay rent. The Court clarified that the Company, regardless of the terms of the lease, was not an ordinary tenant as defined in the Madhya Bharat Act No. 66 of 1950. The High Court's ruling that the Company was not a Government lessee was overturned, affirming the Additional Collector's eviction order based on factual findings.