UNITED BANK OF INDIA vs COOKS AND KELVEY PROPERTIES (P)LTD.

The Supreme Court held that Section 13(1)(a) of the West Bengal Premises Tenancy Act, 1956 does not apply to the case as the appellant, United Bank of India, did not sub-let the premises to the trade union for consideration. The Court found that the Bank retained legal control over the premises and the trade union's possession was deemed constructive, not exclusive. The appeal was allowed, affirming that the Bank's actions did not constitute a transfer of rights for consideration under Section 105 of the Transfer of Property Act.