Mohammad Ahmad & Anr vs Atma Ram Chauhan & Ors

The Supreme Court held that under Section 21(1)(a) of the U.P. Act No. 13 of 1972, a landlord can seek eviction of a tenant for personal bonafide needs. The Court emphasized that the tenant's continued payment of a nominal rent does not preclude the landlord's right to reclaim possession for legitimate needs, especially when the area has transitioned to a commercial zone. The Court upheld the lower court's decision to release the shops in favor of the landlord, affirming the necessity of balancing tenant rights with landlord needs.