SMT. RANI DEVI vs BHOLE NATH AND ORS

The Supreme Court held that under Section 3(a)(2) of the U.P. Urban Building (Regulation of Letting, Rent and Eviction) Act, 1972, married daughters of a deceased tenant are considered tenants and entitled to succeed to the leasehold rights. However, in this case, the married daughters did not assert their rights or participate in the business after the tenant's death, indicating a surrender of their tenancy rights. Therefore, their non-joinder as necessary parties did not vitiate the eviction proceedings initiated by the landlady under Section 21 of the Act, and the appeal was allowed, reinstating the eviction order.