Ram Babu Agarwal vs Jay Kishan Das

The Supreme Court held that Section 13(6) of the Madhya Pradesh Accommodation Control Act, 1961 does not apply to constitutional remedies under Article 136 of the Constitution of India, as statutory provisions cannot control constitutional provisions. The Court found that the High Court erred in rejecting the landlord's claim of bona fide need solely based on the tenant's lack of experience in the footwear business. The Court remanded the matter to the trial Court to reconsider the issue of bona fide need, allowing the parties to present fresh evidence.