Bona fide landlord need and reasonable classification under Article 14 invalidated a rent-control amendment for commercial premises.

An amendment to the East Punjab Urban Rent Restriction Act that removed a landlord's right to evict a tenant from a non-residential building for bona fide personal requirement was held to fail reasonable classification under Article 14. The law treated residential and commercial premises differently without a rational nexus to the Act's object of regulating rent and preventing mala fide evictions. Because the restriction barred recovery of commercial premises even for genuine landlord need, it was found harsh, arbitrary, and discriminatory. The amendment was therefore unconstitutional, and the original eviction ground for bona fide need in respect of non-residential premises stood restored.

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Issues: Whether the amendment to the East Punjab Urban Rent Restriction Act, 1949, which withdrew a landlord's right to seek eviction of a tenant from a non-residential building on the ground of bona fide personal requirement, was violative of Article 14 of the Constitution of India.

Analysis: The Act, as originally enacted, applied its eviction scheme to both residential and non-residential premises and recognised bona fide need of the landlord as a ground for eviction. The amendment created a distinction by removing that ground only in relation to non-residential buildings. The object of the Act was to regulate rent and prevent mala fide evictions, not to confer lifelong protection on tenants of commercial premises. A classification between residential and non-residential premises could not be justified where the landlord's bona fide need stood on the same footing in both cases and the restriction operated without a rational connection to the legislative object. The resulting bar on recovery of commercial premises even for genuine personal need was held to be harsh and arbitrary.

Conclusion: The amendment failed the test of reasonable classification and was unconstitutional as offending Article 14.

Final Conclusion: The appeal succeeded, the High Court's order was set aside, and the original eviction ground for a landlord's bona fide need in respect of non-residential premises stood restored.

Ratio Decidendi: A statutory classification must have an intelligible differentia with a rational nexus to the object of the law, and a rent-control amendment that deprives landlords of eviction for bona fide personal requirement only in respect of non-residential premises, without such nexus, is discriminatory and unconstitutional under Article 14.

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