Residential premises under rent law include company tenants, and acquisition of another residence can trigger eviction.

Under the Delhi Rent Control Act, 1958, the expression "a residence" in Section 14(1)(h) denotes residential premises rather than actual personal occupation. The ground of eviction is therefore triggered when a tenant of residential premises acquires vacant possession of another residence, without requiring proof of physical dwelling or subjective intention to reside. The provision also applies where the tenant is a company or other juristic person, because nothing in its language or object excludes such tenants from its scope. On that construction, the appeal failed and the eviction order was sustained with costs.

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Issues: (i) Whether the expression "a residence" in Section 14(1)(h) of the Delhi Rent Control Act, 1958 refers to the kind of premises let for residential use or requires actual personal residence; (ii) whether Section 14(1)(h) applies where the tenant is a company or other juristic person.

Issue (i): Whether the expression "a residence" in Section 14(1)(h) of the Delhi Rent Control Act, 1958 refers to the kind of premises let for residential use or requires actual personal residence.

Analysis: The phrase had to be read in the context of the definition of "premises" in Section 2(i) and the scheme of the Act. The Act distinguishes residential premises from commercial or other premises, and the eviction ground in Section 14(1)(h) is triggered when a tenant of residential premises acquires vacant possession of another residence. The provision does not turn on actual occupation, physical dwelling, or the tenant's subjective intention regarding use of either property.

Conclusion: The expression "a residence" denotes residential premises, not actual personal residence.

Issue (ii): Whether Section 14(1)(h) applies where the tenant is a company or other juristic person.

Analysis: The English authorities relied upon by the appellant were distinguished because they were based on statutes protecting dwelling houses and personal occupation. The Delhi Act protects premises generally and recognises tenancy, possession, and eviction rights in a wider sense, including constructive possession. Nothing in the language or object of Section 14(1)(h) excludes a company from being a tenant of residential premises or from attracting the eviction ground on acquisition of another residence. Excluding companies would frustrate the legislative object of limiting protection to one residential accommodation.

Conclusion: Section 14(1)(h) applies to residential premises even when the tenant is a company.

Final Conclusion: The appeal failed, and the eviction order was sustained with costs.

Ratio Decidendi: Under the Delhi Rent Control Act, 1958, the expression "a residence" in Section 14(1)(h) means residential premises, and the ground of eviction applies to a company as tenant if it acquires vacant possession of another residence.

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