Temporary statutory rights can survive expiry, and a demolition notice may still support eviction under the rent law.

Rights and obligations created under a temporary statute may survive its expiry where the statutory scheme shows an enduring intention, and a building-permission condition attached to ownership can remain enforceable after the Act ends. A demolition notice issued by the Municipal Commissioner was treated as having valid statutory origin because it could be traced to the town-planning framework, and it therefore qualified as an order of demolition by the competent authority under the rent law. The premises were also held to be required for immediate demolition notwithstanding objections about the town planning scheme, so the demolition-based eviction ground was established.

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Issues: (i) Whether rights and obligations created under the temporary Bombay Act, 1944, including the condition attached to the building permission, survived the expiry of that Act and authorised the Municipal Commissioner to issue the demolition notice; (ii) whether the demolition notice issued by the Municipal Commissioner constituted an order of demolition by the local or competent authority within section 13(1)(hhh) of the Bombay Rents Act, 1947; (iii) whether the premises were required for the immediate purpose of demolition notwithstanding the status of the town planning scheme and related objections.

Issue (i): Whether rights and obligations created under the temporary Bombay Act, 1944, including the condition attached to the building permission, survived the expiry of that Act and authorised the Municipal Commissioner to issue the demolition notice.

Analysis: The effect of the expiry of a temporary statute depends on the construction of the statute and the nature of the rights or obligations created by it. Rights of an enduring character, once vested, do not necessarily perish with the statute. The permission granted under section 3 of the Bombay Act, 1944 was expressly subject to a condition that the temporary structures would be removed when required, and section 8 attached that benefit and burden to the ownership of the structure. Those rights and obligations were treated as permanent in operation and not confined to the life of the Act.

Conclusion: The condition survived the expiry of the Bombay Act, 1944, and the Municipal Commissioner remained competent to act on it.

Issue (ii): Whether the demolition notice issued by the Municipal Commissioner constituted an order of demolition by the local or competent authority within section 13(1)(hhh) of the Bombay Rents Act, 1947.

Analysis: The notice was traceable to the statutory scheme under the Bombay Town Planning Act, 1954 and the special regulations made thereunder, which authorised removal of temporary structures that contravened the scheme or were required to be removed under the scheme. A notice does not fail merely because it refers to an incorrect source if the power can be traced to a valid statutory source. On that basis, the notice was treated as having statutory genesis and as an enforceable direction for demolition.

Conclusion: The notice constituted an order of demolition by the competent authority within section 13(1)(hhh).

Issue (iii): Whether the premises were required for the immediate purpose of demolition notwithstanding the status of the town planning scheme and related objections.

Analysis: Clause (hhh) of section 13(1) was distinguished from the landlord-driven demolition ground in clause (hh); it was meant to operate where demolition was compelled by a local or competent authority in public interest. The suspension of some regulations did not amount to abandonment of the scheme, and the proposed variation had no present legal effect. The Court also held that the evidence relied on by the appellants did not negate the statutory requirement of immediacy.

Conclusion: The premises were required for the immediate purpose of demolition, and the appellants' objections failed.

Final Conclusion: The landlords established the statutory ground for eviction under section 13(1)(hhh), and the appellate challenge to the demolition-based eviction decree did not succeed.

Ratio Decidendi: Rights and obligations validly created under a temporary statute may survive its expiry where the statutory scheme shows an enduring intention, and a demolition notice traceable to a valid statutory source can sustain eviction under the demolition ground in the rent law.

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