Broad government premises tenancy law extends beyond residential units and defeats ownership claims after lease breach.

The West Bengal Government Premises (Tenancy Regulation) Act, 1976 is not confined to residential occupation; its broad definitions of "Government premises" and "premises" extend to industrial and other non-residential premises, while the later 1984 enactment confirms that any residential limitation was not inherent in the 1976 Act. On breach of lease covenants, including prolonged non-use of an industrial unit and cessation of manufacturing activity, Section 3(2)(i) operates in general terms to bring about automatic termination. A contractual clause promising ownership after 30 years cannot be relied on once the tenant has violated the earlier lease conditions, so no enforceable right to acquire the sheds arises.

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Issues: (i) Whether the West Bengal Government Premises (Tenancy Regulation) Act, 1976 applies only to residential premises or also to industrial and other non-residential premises; (ii) Whether the appellant's tenancy stood automatically terminated for violation of the lease conditions and whether it could claim ownership under the lease deed.

Issue (i): Whether the West Bengal Government Premises (Tenancy Regulation) Act, 1976 applies only to residential premises or also to industrial and other non-residential premises.

Analysis: The definition of "Government premises" in Section 2(a) is broad and covers any premises owned by the State Government or a Government undertaking, save for the express exclusion of official residences. The definition of "premises" in Section 2(c) is likewise comprehensive and uses expansive language, including buildings, huts, parts thereof, seats in rooms, gardens, grounds, godowns, out-houses, furniture and fixtures. The statutory text does not confine the Act to residential tenancies. By contrast, the later 1984 enactment expressly limited its scope to premises used or intended to be used for residential purposes, which reinforced that the 1976 Act was not so restricted. Clause 3(2)(i) of the Act, dealing with violation of lease terms, is also couched in general terms and is not confined to residential leases.

Conclusion: The Act applies to industrial and other non-residential premises as well, and not merely to residential premises.

Issue (ii): Whether the appellant's tenancy stood automatically terminated for violation of the lease conditions and whether it could claim ownership under the lease deed.

Analysis: The factual findings recorded by the authority showed that the industrial unit remained closed for a long period and no manufacturing activity was carried on, supported by the disconnection of electricity connections and outstanding dues. This amounted to a clear breach of the lease covenants, attracting automatic termination under Section 3(2)(i) of the Act. The claimed right to ownership after 30 years under clause VI(b) of the lease deed was expressly subject to the earlier covenants. Once the appellant had violated those covenants, it could not invoke clause VI(b) to claim ownership of the sheds.

Conclusion: The tenancy had automatically terminated for breach of lease conditions, and the appellant had no enforceable right to acquire ownership of the demised sheds.

Final Conclusion: The statutory scheme was held to govern non-residential Government premises as well, and the appellant's continued breach of the lease justified eviction and defeated its claim to ownership.

Ratio Decidendi: A statute with an expansive definition of Government premises and premises must be construed according to its wide language, and where the lease terms are violated, tenancy stands automatically terminated under the Act notwithstanding a contractual claim to future ownership.

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