Bona fide landlord need assessed on filing date, with later developments considered only if they materially affect relief.

In eviction proceedings under Section 21(1)(a) of the U.P. Urban Buildings (Regulation of Letting, Rent and Eviction) Act, 1972, the Supreme Court reiterated that the genuineness of a landlord's bona fide requirement is ordinarily judged on the date of the eviction application. Subsequent developments during the pendency of the case may be considered only cautiously and only if they materially affect the entitlement to relief. On the facts, the tenant's later development did not extinguish the landlord's established need, and the concurrent findings on bona fide requirement were left undisturbed; the eviction order was upheld.

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Issues: Whether subsequent developments during the pendency of rent control proceedings can defeat a landlord's bona fide requirement for eviction under Section 21(1)(a) of the U.P. Urban Buildings (Regulation of Letting, Rent and Eviction) Act, 1972.

Analysis: The crucial date for judging the genuineness of the landlord's need is ordinarily the date of the eviction application. Subsequent events may be noticed only cautiously and only where they materially affect the entitlement to relief. The later development relied upon by the tenant did not completely eclipse the landlord's need as originally established, and the concurrent findings of the fact-finding authorities on bona fide requirement remained undisturbed.

Conclusion: Subsequent developments did not dislodge the landlord's bona fide need, and the eviction order was upheld.

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