Mohinder Prasad Jain vs Manohar Lal Jain

The Supreme Court held that under Section 13 of the Haryana Urban (Control of Rent and Eviction) Act, 1973, a landlord can seek eviction of a tenant from a non-residential building on the ground of bona fide personal requirement, as previously established in Harbilas Rai Bansal vs. State of Punjab [(1996) 1 SCC 1] and reaffirmed in Rakesh Vij vs. Dr. Raminder Pal Singh Sethi & Ors. [(2005) 8 SCC 504]. The Court found that the Appellate Authority correctly determined the bona fide requirement of the respondent, despite the Rent Controller's initial dismissal. The appeal was allowed, affirming the right of the landlord to evict the tenant for personal use of the premises.