Broad eviction ground interpretation under rent control law extends to non-residential premises and limits delay objections.

Clause 13(3)(v) of the C.P. & Berar Letting of Houses and Rent Control Order, 1949 was construed broadly to cover non-residential buildings because the definition of "house" included residential and non-residential premises, and the Explanation could not curtail the main text. The qualifying words "does not reasonably need the house" were treated as attaching primarily to the alternative accommodation limb, and the finding that the alternative premises did not reasonably meet the tenant's needs was upheld. The eviction request was not defeated by delay, as it was within limitation and supported by later circumstances. The eviction orders were sustained.

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Issues: (i) whether clause 13(3)(v) of the C.P. & Berar Letting of Houses and Rent Control Order, 1949 applied to non-residential buildings; (ii) whether the expression "does not reasonably need the house" qualified only the ground of securing alternative accommodation or also the ground of leaving the area for four months; (iii) whether the eviction application could be rejected on the ground of delay.

Issue (i): whether clause 13(3)(v) of the C.P. & Berar Letting of Houses and Rent Control Order, 1949 applied to non-residential buildings.

Analysis: The term "house" was defined broadly to include a building or part of a building, whether residential or non-residential. The Explanation added to the clause dealt only with a limited class of residential houses and created a legal fiction for one aspect of alternative accommodation, but it did not cut down the main language of the clause. The Explanation did not justify excluding non-residential premises from the ambit of the ground relating to securing alternative accommodation.

Conclusion: The clause applied to non-residential buildings also, and the contention of the tenant failed.

Issue (ii): whether the expression "does not reasonably need the house" qualified only the ground of securing alternative accommodation or also the ground of leaving the area for four months.

Analysis: The punctuation and structure of the clause indicated that the qualifying words attached to the first limb concerning alternative accommodation. In any event, the concept of alternative accommodation itself necessarily includes the requirement that the other premises must reasonably meet the tenant's needs. The findings of fact recorded below were against the tenant on that aspect.

Conclusion: The qualification primarily governed the alternative accommodation limb, and the finding against the tenant on reasonable need stood confirmed.

Issue (iii): whether the eviction application could be rejected on the ground of delay.

Analysis: The application was within limitation, and the evidence showed later circumstances justifying the belated action, including the family partition and the tenant's changing circumstances. The cited precedent on waiver and delay did not assist the tenant on these facts.

Conclusion: The plea of delay was rejected.

Final Conclusion: The orders permitting eviction were sustained and the tenant's appeals failed.

Ratio Decidendi: A statutory ground for eviction framed in broad terms cannot be restricted by an explanation confined to a narrower class of cases, where the text and structure show that the explanation was intended only to clarify, not to curtail, the main substantive provision.

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