Statutory family definition may include a foster son where upbringing and conduct establish a real familial relationship.

The statutory definition of "member of his family" in a Rent Control Act is not mechanically confined by the word "means"; it must be read in context and with the opening qualification that the context may require a broader meaning. Family can extend beyond blood or marital ties where the facts show a real familial relationship created by upbringing, support, treatment as a son, and holding out as such. On those facts, a foster son may qualify as a family member, so an eviction petition based on bona fide family requirement was maintainable.

---

---

Issues: Whether a foster son can be treated as a member of the landlord's family within the meaning of the relevant definition in the Rent Control Act, so as to sustain an eviction petition based on the landlord's and such foster son's bona fide requirement.

Analysis: The definition of "member of his family" in the Act uses the word "means", but it must still be read in the setting of the statute and the opening words of the definition section, namely, "unless the context otherwise requires". A definition clause is not invariably rigid in every context. The expression "family" is flexible and may, depending on the statutory purpose and surrounding facts, extend beyond blood or marital relations. A foster son is not necessarily excluded merely because he is not a natural son; where a child is brought up from infancy, treated as a son, supported, educated, and held out as such, the relationship may satisfy the statutory idea of family. On the facts, Arunachala Bakthar was the husband's brother's son, was brought up by the couple, lived with them, assisted in the business, and was treated by the husband as his own son, including in the testamentary dispositions.

Conclusion: A foster son can, in appropriate facts, fall within the meaning of "member of his family" under the Act. On the facts of the case, Arunachala Bakthar was such a member, and the eviction petition on the ground of bona fide requirement was maintainable.

Final Conclusion: The appeal failed, and the landlord's right to seek eviction on the basis of family requirement was upheld.

Ratio Decidendi: A statutory definition of family, though expressed in restrictive language, must yield to context and may include a foster son where the facts show a real familial relationship created by upbringing, care, and treatment as a son.

---