Broad meaning of business under rent law supports eviction where the landlord needs rented land for a library building.

Under the East Punjab Urban Rent Restriction Act, the term "business" in the rented-land provisions is used in a broad sense and is not confined to profit-making commercial activity; it may include charitable or public-oriented activity such as organising a library. The landlord's right to seek eviction for own use is not limited by any rule against constructing a building on the rented land, if the nature of the business requires such construction. Where bona fide need for a sanctioned library building is shown, eviction can be sustained even if the land is intended for construction.

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Issues: (i) Whether the word "business" in the definition of "rented land" and in the eviction provision is confined to commercial activity carried on with profit motive or extends to a wider non-commercial use; (ii) whether a landlord seeking eviction of rented land for its own use may put up a construction on the land for carrying on that business, including construction of a library building.

Issue (i): Whether the word "business" in the definition of "rented land" and in the eviction provision is confined to commercial activity carried on with profit motive or extends to a wider non-commercial use.

Analysis: The expression "business" is not a term of fixed or technical meaning and its scope depends on context. The relevant provisions were held to use the word in a wider sense. The association's objects, together with the Government's allotment of the plot for a library building, showed that organising a library was one of its activities. The concept of business under the Act was not limited to profit-making commerce and could include charitable or public-oriented activity.

Conclusion: The word "business" in the Act is not confined to commercial profit-making activity and includes the society's activity of organising a library.

Issue (ii): Whether a landlord seeking eviction of rented land for its own use may put up a construction on the land for carrying on that business, including construction of a library building.

Analysis: The statutory scheme requires that rented land be required for the landlord's own use for business or trade, but it does not prescribe the manner in which that business must thereafter be carried on. The earlier restrictive view was reconsidered. It was held that if the nature of the business requires a structure, the landlord is not barred from raising such construction. The bona fide requirement of the society for a sanctioned library building was established on the record, and the availability of some other plot allotted for a different purpose did not defeat the claim.

Conclusion: A landlord may obtain eviction of rented land for a business that requires construction on the land, and the society's requirement for a library building was covered by the provision.

Final Conclusion: The society's claim satisfied the statutory conditions for eviction of rented land, the revision succeeded, and the order of eviction was restored.

Ratio Decidendi: Under the East Punjab Urban Rent Restriction Act, "business" in the rented-land provisions is used in a broad sense, and a landlord who proves bona fide requirement for his own business may obtain eviction even where that business necessarily requires construction on the rented land itself.

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