Prabhudas Damodar Kotecha & Ors vs Manharbala Jeram Dmodar & Anr

The Supreme Court held that a suit filed by a licensor against a gratuitous licensee under Section 41(1) of the Presidency Small Causes Courts Act, 1882 is maintainable before a Small Causes Court, thereby overruling the Bombay High Court's decision in Ramesh Dwarikadas Mehra v. Indirawati Dwarika Das Mehra. The Court established that the term 'licensee' in Section 41(1) includes gratuitous licensees, thus affirming the jurisdiction of the Small Causes Court in such matters. The judgment clarified the interpretation of the PSCC Act in relation to the Rent Act, allowing the suit to proceed in the Small Causes Court.