Forfeiture by denial of title requires a prior act by the lessor to determine the lease, not the suit itself.

Denial of the landlord's title can support forfeiture only where the denial is clear and unambiguous, and mere non-payment of rent is insufficient by itself. Section 111 of the Transfer of Property Act requires the lessor to do an act showing an intention to determine the lease before suit is filed; the institution of the suit cannot itself satisfy that condition precedent. On the stated facts, even if mortgaging the house and land amounted to denial of title, the lessor's determining act still had to precede the proceedings, and filing the suit did not amount to valid compliance.

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Issues: Whether, where a lessee is alleged to have denied the landlord's title, the institution of the suit itself amounts to the lessor's act showing an intention to determine the lease under Section 111 of the Transfer of Property Act.

Analysis: Mere non-payment of rent was held insufficient to work a forfeiture, and the alleged denial of title had to be clear and unambiguous. Even assuming that the mortgaging of the house and land amounted to denial of title, the statutory requirement was that the lessor must do an act showing an intention to determine the lease. That act had to be done before the suit was brought; filing the suit could not itself satisfy the condition precedent.

Conclusion: The institution of the suit was not sufficient compliance with Section 111 of the Transfer of Property Act, and the lessor's determining act had to precede the suit.

Ratio Decidendi: When forfeiture is based on denial of title, the lessor must perform a prior act manifesting an intention to determine the lease, and the suit itself cannot be treated as that act.

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