Purposive reading of landlord under rent law requires written authority before an agent can sue for eviction.

The Rent Act's definition of landlord requires a purposive reading, so an agent cannot displace the owner as the natural landlord merely to institute eviction and rent recovery proceedings. A person claiming to act for the owner must first show written authorisation, such as a power of attorney or equivalent documentary proof, before maintaining such a suit on the owner's behalf. On the facts, the respondent had not proved such authorisation from the trust, so entitlement to sue was not established. The matter was directed to be examined by the Trial Court after production of documentary proof and impleadment of the trust.

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Issues: Whether the respondent, as an alleged agent of the trust and not the owner, was entitled to be treated as the landlord and maintain a suit for eviction and recovery of rent under Section 3(iii) of the Rajasthan Premises (Control of Rent & Eviction) Act, 1950.

Analysis: The definition of landlord in the Rent Act was held to require a purposive construction rather than a literal one. A literal reading would permit an agent to displace the owner and maintain eviction proceedings even where the owner did not wish to evict the tenant, which was considered an absurd result. The Court held that the owner remains the natural landlord, and where a person claims only to act for the owner, there must be documentary proof of authorisation, such as a power of attorney or other written authority, before such person can institute an eviction suit on behalf of the owner. On the facts, the respondent had not established written authorisation from the trust.

Conclusion: The respondent's entitlement to maintain the suit on behalf of the trust was not established; the matter was required to be examined by the Trial Court after allowing production of documentary proof and impleadment of the trust.

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