Rent Control eviction depends on statutory grounds alone; prior tenancy termination notice is unnecessary unless the Act requires it.

Rent Control legislation functions as a special code that curtails common-law and contractual eviction rights, so eviction must rest on a statutory ground where the Act prescribes specific grounds and procedure. Prior notice terminating the tenancy under Section 106 of the Transfer of Property Act is not required unless the special statute expressly makes such notice mandatory. If the tenant remains protected under the Rent Act after the contractual tenancy ends, the landlord may proceed on the statutory ground alone, and insistence on contractual termination is treated as unnecessary surplusage.

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Issues: Whether a notice to quit under Section 106 of the Transfer of Property Act, 1882 is necessary before seeking eviction of a tenant under a State Rent Control Act that itself specifies the grounds and procedure for eviction.

Analysis: The governing principle is that Rent Control legislation materially curtails the landlord's common-law and contractual rights and provides a special code for eviction. Where the statute permits eviction only on specified grounds, and the tenant continues in occupation under the protective scheme of the Act even after the contractual tenancy has ended, the landlord's right to recover possession depends on establishing a statutory ground for eviction, not on prior determination of the lease under the Transfer of Property Act. A notice under Section 106 becomes necessary only where the special statute itself requires such notice; otherwise, insisting on contractual termination is an unnecessary formality and a surplusage. The Court examined the scheme of the Tamil Nadu Rent Act and similar State enactments and held that the statutory ground of eviction, once made out, is sufficient to sustain the proceeding.

Conclusion: A notice under Section 106 of the Transfer of Property Act is not mandatory for eviction under the Tamil Nadu Rent Act in the absence of a specific statutory requirement; the appeal was therefore dismissed.

Ratio Decidendi: Where a special Rent Control Act prescribes the grounds and procedure for eviction and protects the tenant's continued occupation notwithstanding termination of the contractual tenancy, eviction may be sought on the statutory ground alone and prior notice under Section 106 of the Transfer of Property Act is not unless expressly required by the statute.

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