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Issues: Whether a tenant's denial of the landlord's title, made in the written statement in eviction proceedings under the Andhra Pradesh Buildings (Lease, Rent and Eviction) Control Act, 1960, can itself furnish a ground for eviction, and whether such denial must be anterior to the eviction petition.
Analysis: Section 10(2)(vi) of the Act expressly treats denial of the landlord's title, when not bona fide, as a ground for eviction. The requirement is that the denial must be clear and unequivocal; the Act does not impose any further condition that the denial must have existed before the filing of the petition. The reasoning based on forfeiture under the Transfer of Property Act does not control the special scheme of the rent legislation. Since the rent enactment itself permits eviction on this ground, the landlord can rely on a denial made in the same proceedings. The absence of an amendment to the petition did not defeat the claim, because the issue was framed, tried, and fully contested by the parties.
Conclusion: The denial of title in the written statement constituted a valid ground for eviction under the Act, and it was not necessary that the denial should be anterior to the eviction petition.
Final Conclusion: The tenant's challenge failed, and the eviction order was sustained on the ground of non-bona fide denial of the landlord's title.
Ratio Decidendi: Where the rent statute itself makes non-bona fide denial of the landlord's title a ground for eviction, such denial may be relied upon even if it is made in the eviction proceedings themselves, provided it is clear, unequivocal, and duly put in issue.