Bona fide requirement under rent law includes other suitable accommodation; non-disclosure was not fatal on these facts.

Under Section 14(1)(e) of the Delhi Rent Control Act, bona fide requirement includes examination of whether the landlord has any other reasonably suitable residential accommodation, so the pleadings and surrounding facts must be read together to test the genuineness of the need. The landlord's non-disclosure of accommodation at Subzi Mandi was not fatal where both sides understood the real controversy and relevant material was before the Court. The High Court could interfere in revision under the proviso to Section 25B(8) because the Rent Controller had treated non-disclosure as decisive on a wrong legal premise; revisional power extends to correcting errors of law and ensuring that findings rest on a proper legal basis.

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Issues: Whether the landlord's non-disclosure of accommodation at Subzi Mandi was fatal to an eviction petition under Section 14(1)(e), and whether the High Court could interfere in revision under the proviso to Section 25B(8) of the Delhi Rent Control Act.

Analysis: The requirement under Section 14(1)(e) is not confined to a bare plea of bona fide need; it also includes the question whether the landlord has any other reasonably suitable residential accommodation. These matters are interconnected, and the Court may examine the surrounding facts to determine whether the claim is genuine. The High Court was justified in reappraising the record because the Rent Controller treated the alleged non-disclosure as fatal on a wrong legal premise. The revisional power, though limited, extends to correcting errors of law and to examining whether the finding rests on a proper legal basis. The absence of perfect pleadings was not decisive where both sides had understood the real controversy and placed the relevant material before the Court.

Conclusion: The eviction order was upheld, the appeal was dismissed, and the landlord's non-disclosure was held not to be fatal in the facts of the case.

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