Article 227 limits supervisory review: concurrent eviction findings based on bona fide need and comparative hardship were restored.

Under Article 227 supervisory jurisdiction, the High Court could not disturb concurrent factual findings supporting eviction unless they were perverse or wholly unreasonable. The landlord's bona fide and reasonable requirement under Section 13(1)(g) of the Bombay Rents, Hotel and Lodging House Rates Control Act was supported by admitted circumstances, including a small family accommodation against a larger family need, and the tenant failed to rebut the presumption of bona fides. Comparative hardship under Section 13(2) also favoured eviction. The High Court erred by reappreciating evidence and relying on material that did not justify supervisory interference, so the eviction decree was restored.

---

---

Issues: Whether the High Court, in exercise of supervisory jurisdiction under Article 227 of the Constitution of India, could interfere with concurrent findings supporting eviction on the ground of bona fide and reasonable requirement under Section 13(1)(g) of the Bombay Rents, Hotel and Lodging House Rates Control Act, 1947, and whether the decree of eviction was rightly restored.

Analysis: The ground under Section 13(1)(g) requires the landlord's need for occupation to be both reasonable and bona fide, and the Court must also consider comparative hardship under Section 13(2). On the admitted facts, the landlady was living in a small flat with a large family, while the tenant occupied another flat in the same locality. These circumstances supported the reasonableness of the requirement and raised a presumption of bona fides, which was not rebutted. The High Court exceeded the limits of Article 227 by upsetting findings of fact recorded by the appellate authority and by relying on fresh material not shown to justify supervisory interference. The perceived discrepancy regarding the son's flat and the absence of a specific plinth-area assertion did not furnish a legal basis to quash the eviction decree.

Conclusion: The High Court was not justified in interfering with the eviction decree under Article 227, and the decree was rightly restored in favour of the landlady.

Final Conclusion: The appeals succeeded, the High Court's judgment was set aside, and the eviction order stood restored with time granted to the tenant for surrender on undertaking.

Ratio Decidendi: In supervisory jurisdiction under Article 227, the High Court cannot reappreciate evidence or disturb factual findings of the fact-finding authority unless they are perverse or wholly unreasonable; a landlord's bona fide and reasonable requirement, once supported by admitted circumstances and unrebutted, can sustain eviction under the rent control statute.

---