Forfeiture of tenancy requires a clear, unequivocal denial of title; contextual statements did not establish renunciation here.

A lease is forfeited under Section 111(g) of the Transfer of Property Act only where the lessee makes a clear and unequivocal disclaimer of the landlord's title to the landlord's knowledge. The stated principle can apply even where the Act does not in terms govern, but the alleged renunciation must be examined in context. On the facts described, the statements in the compensation proceedings and related documents, read as a whole and against the background of long possession, nominal rent, the earlier declaration under the Oudh Estates Act, and the asserted heritable and transferable interest, did not amount to an unmistakable denial of the Government's reversionary rights. The references to ownership were capable of referring to a permanent leasehold claim, so forfeiture was not established.

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Issues: Whether the appellant's statements in the compensation proceedings and related documents amounted to a clear and unequivocal denial of the Government's title so as to work a forfeiture of the tenancy.

Analysis: Section 111(g) of the Transfer of Property Act embodies the rule that a lease is determined by forfeiture where the lessee renounces his character by setting up title in himself or in a third person, and the principle applies even where the Transfer of Property Act does not in terms govern. The controlling requirement is that the disclaimer of the landlord's title must be clear, unequivocal, and made to the landlord's knowledge. Reading the impugned statements as a whole and in the background of the long enjoyment of the property, the nominal rent, the earlier declaration under Section 32A of the Oudh Estates Act, 1869, and the plaintiff's consistent assertion of a heritable and transferable interest, the words used in the compensation application did not necessarily amount to an assertion of absolute ownership in derogation of the Government's reversionary rights. The references to the land as "belonging to me," to ownership, and to title in the plaint and subsequent application were capable of referring to the claimed permanent leasehold interest and were not shown to be an unequivocal repudiation of the tenancy.

Conclusion: The appellant did not incur forfeiture of the tenancy, and the termination of his rights on that ground was not justified.

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