PULIN BEHARI PAL vs MAHADEB DUTTA .

The Supreme Court held that under Section 13(1)(a) and Section 16 of the West Bengal Premises Tenancy Act, 1956, a landlord's previous written consent is mandatory for the creation of sub-tenancy, and failure to obtain such consent constitutes a valid ground for eviction. The Court clarified that mere acceptance of rent by the landlord after knowledge of sub-letting does not amount to a waiver of the right to evict the tenant. The appeal by the tenant was dismissed, affirming the lower court's decision to grant eviction based on sub-letting without consent.