Strict compliance with lease renewal terms and statutory renewal conditions defeated tenancy renewal claims and upheld eviction relief.

A lease renewal clause must be strictly and fully complied with, and a renewal notice that does not satisfy every contractual condition cannot validly extend the tenancy. The correspondence relied on was held insufficient to create a renewed lease by letter. Statutory renewal under the ESSO (Acquisitions of Undertakings in India) Act, 1974 applies only where the property appertains to Esso's business in India; a residential flat used for officers did not meet that requirement. On those facts, no automatic renewal arose, and the challenge to eviction failed, leaving possession and consequential reliefs to the respondent.

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Issues: (i) Whether the lease was validly renewed under the contractual renewal clause; (ii) Whether the lease stood renewed by operation of the ESSO (Acquisitions of Undertakings in India) Act, 1974.

Issue (i): Whether the lease was validly renewed under the contractual renewal clause.

Analysis: The renewal clause had to be read as a whole, and any exercise of the option had to comply with all its terms. The renewal notice did not evince compliance with the entire clause, including the obligations attached to renewal. The correspondence relied on did not amount to a proper and complete exercise of the contractual option, and there was also no valid creation of a renewed lease by mere letter.

Conclusion: The lease was not validly renewed under the contractual renewal clause.

Issue (ii): Whether the lease stood renewed by operation of the ESSO (Acquisitions of Undertakings in India) Act, 1974.

Analysis: The statutory renewal provision applied only where the property appertained to the business carried on by Esso in India. On the evidence, the flat was let and used for residential purposes for officers of the company and did not form part of Esso's business. The statutory scheme did not provide for automatic renewal in such circumstances, and the conditions for renewal were not fulfilled.

Conclusion: The lease did not stand renewed by operation of the Act.

Final Conclusion: The challenge to the decree for eviction failed, and the appellate court affirmed the respondent's entitlement to recover possession and consequential reliefs.

Ratio Decidendi: A lease renewal clause must be strictly and fully complied with, and a statutory renewal under the ESSO Act arises only where the property concerned appertains to the business carried on by Esso in India and the statutory conditions for renewal are satisfied.

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