Revisional review and bona fide landlord need sustained eviction where factual findings were legally infirm and later events were considered.

Under a revisional power framed around legality and propriety, the High Court may reappraise evidence and disturb factual findings where they are legally infirm, so it was competent to interfere with the Appellate Authority's conclusions. On the eviction merits, the landlords' bona fide requirement for additional accommodation was upheld because the need was found genuine and reasonable, and later developments could be considered without displacing the finding of insufficient accommodation. The appeal therefore failed, and the eviction order was restored.

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Issues: (i) Whether the High Court, in revision under Section 15(5) of the East Punjab Rent Restriction Act, 1949, could interfere with findings of fact recorded by the Appellate Authority and reappraise the evidence; (ii) Whether the landlords had established a bona fide requirement for additional accommodation and whether subsequent events could be taken into account.

Issue (i): Whether the High Court, in revision under Section 15(5) of the East Punjab Rent Restriction Act, 1949, could interfere with findings of fact recorded by the Appellate Authority and reappraise the evidence.

Analysis: The revisional power under Section 15(5) extends to examination of the legality and propriety of the order under revision. That jurisdiction is wider than a narrow legality review and, in an appropriate case, permits scrutiny of factual findings where they are infirm in law. The High Court was therefore not barred from reappraising the evidence merely because the matter involved findings of fact.

Conclusion: The High Court was competent to interfere with the appellate findings in revision.

Issue (ii): Whether the landlords had established a bona fide requirement for additional accommodation and whether subsequent events could be taken into account.

Analysis: Bona fide requirement is a question of fact, but the need must be genuine, honest, and reasonable in the legal sense. The High Court found that the Appellate Authority had relied on irrelevant considerations and also took note of later developments affecting the landlords' accommodation needs. Courts may notice subsequent events to mould relief, and the additional material did not displace the finding that the accommodation in the landlords' hands was insufficient.

Conclusion: The landlords' bona fide requirement was upheld, and the subsequent events did not defeat the eviction claim.

Final Conclusion: The appeal failed on both the scope of revision and the merits of the eviction claim, and the eviction order stood restored.

Ratio Decidendi: Under a revisional provision framed in terms of legality and propriety, the High Court may reappraise evidence and disturb factual findings where they are legally infirm, and bona fide landlord requirement may be assessed with due regard to relevant subsequent events.

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