Crystallized eviction rights survive amalgamation when the scheme preserves pending proceedings and the landlord's need continues.

Where a landlord's eviction right had already crystallized into a confirmed decree before amalgamation, the transferee company could continue and enforce the proceedings if the amalgamation scheme preserved pending suits, appeals and revisions. The article states that such amalgamation does not extinguish the landlord's accrued rights under rent control and property law. It further notes that subsequent events in revision do not automatically displace a finding of bona fide requirement, particularly where the landlord's need continues and no factual foundation supports a plea based on other properties. The stated legal effect is that eviction remains enforceable notwithstanding the merger.

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Issues: (i) Whether the amalgamation of the landlord company with another company during the pendency of revision defeated the accrued right to eviction and prevented the transferee company from continuing the proceedings; (ii) Whether the subsequent event of amalgamation required denial of eviction on the ground of other available properties or change in requirement.

Issue (i): Whether the amalgamation of the landlord company with another company during the pendency of revision defeated the accrued right to eviction and prevented the transferee company from continuing the proceedings.

Analysis: The eviction petition had been filed and allowed on the ground of bona fide requirement, and the appellate authority had confirmed the order before amalgamation. The Scheme of Amalgamation expressly provided that pending suits, appeals, revisions and other proceedings would not abate and could be continued by or against the transferee company. The right to evict had already crystallized in the decree and, once the transferor company merged, its rights devolved on the transferee company. The Court distinguished cases where amalgamation of a tenant company caused forfeiture or subletting consequences, holding that a landlord's amalgamation does not extinguish the landlord's rights under rent control law or the transfer of property law.

Conclusion: The amalgamation did not defeat the accrued eviction right, and the transferee company was entitled to continue and enforce the proceedings.

Issue (ii): Whether the subsequent event of amalgamation required denial of eviction on the ground of other available properties or change in requirement.

Analysis: The Court held that subsequent events are not automatically decisive in revision, especially where the revisional jurisdiction is limited and the delay in disposal should not prejudice vested rights created by a confirmed eviction decree. The landlord's requirement had not ceased or been satisfied, and the amalgamation itself was part of the continuation of the same business requirement. The new plea based on ownership of other properties was rejected because the proviso relied upon was inapplicable to the pending revision and, in any event, the factual foundation for occupation of such properties was absent.

Conclusion: The subsequent event did not displace the finding of bona fide requirement or bar eviction.

Final Conclusion: The eviction order was upheld, the tenant's challenge failed, and the decree-holder's rights remained enforceable notwithstanding the amalgamation.

Ratio Decidendi: Where a landlord's right to eviction has already crystallized into a decree, a subsequent amalgamation does not extinguish that right if the scheme preserves pending proceedings and the landlord's requirement continues to subsist.

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