Rent Receipt Is Enough — Landlord Need Not Prove Title to Evict Tenant: Supreme Court Reinstates Eviction Under Karnataka Rent Act

“In Rent Control Proceedings, Landlord’s Ownership is Irrelevant Where Rent Is Paid” —  On 9th September 2025, the Supreme Court of India emphatically held that production of rent receipts signed by a landlord constitutes prima facie proof of the landlord-tenant relationship, and a dispute over ownership or title cannot defeat an eviction proceeding under the Karnataka Rent Act, 1999.

Setting aside the High Court’s reversal of an eviction order, the Court ruled:
“When rent has been paid and acknowledged, the tenant cannot challenge the jural relationship by raising doubts over ownership or ancestral lineage.”

“Landlord Is One Who Receives Rent, Not Necessarily the Owner” — Supreme Court Restricts Scope of High Court’s Revisional Powers

The eviction proceedings were initiated by H.S. Puttashankara against Yashodamma, who had continued to occupy the suit premises after the death of her mother, Mysore Lingamma — a tenant under the appellant’s father. The Rent Controller, after considering rent receipts produced by the appellant, allowed eviction under Section 27(2)(a), (e), (g) and (o) of the Karnataka Rent Act, 1999.

However, in a House Rent Revision Petition, the Karnataka High Court set aside the order, reasoning that the appellant failed to prove his lineage from the original owner Sri Banappa and questioning the genuineness of rent receipts, as the respondent’s son denied his signature.

This approach was expressly disapproved by the Supreme Court, which held:
“The High Court misdirected itself in revisional jurisdiction by indulging in a fact-finding exercise concerning the appellant’s title — a question wholly irrelevant to an eviction petition under the Rent Act.”

“Section 43 Allows Court to Accept Rent Receipt as Prima Facie Proof of Tenancy” — Apex Court Reinforces Legislative Intent

Quoting Section 43 of the Karnataka Rent Act, 1999, the Court noted: “Where in any proceeding before the Court, a contention is raised denying the existence of relationship of landlord and tenant... it shall be lawful for the Court to accept... a receipt of acknowledgement of payment of rent purported to be signed by the landlord as prima-facie evidence of relationship and proceed to hear the case.”

The Court emphasized that the Rent Controller had rightly invoked this provision by relying on rent receipt dated 20.07.2015, which acknowledged payment of rent for the period from 01.02.2013 to 31.05.2014.

The Bench observed:
“When such evidence exists, the Court is not required to probe into ownership or ancestry. It must proceed on the presumption of tenancy.”

“Title Disputes Must Go to Civil Court — Not a Bar to Eviction Based on Rent Receipt”

The respondent had claimed that the property belonged to Ankalappa Mutt, and that her tenancy was under the Mutt, not the appellant. She also disputed the release deed dated 04.11.2015, under which the appellant claimed ownership.

However, the Court made it unequivocally clear that such contentions had no place in eviction proceedings: “The Rent Controller is not empowered to adjudicate title disputes. Once the rent receipt is produced, the Court must presume tenancy, and disputes over ownership must be agitated separately before a competent civil court.”

The judgment reinforces the distinction between ownership and tenancy, asserting that: “A landlord, under Section 3(e) of the Act, means anyone who receives or is entitled to receive rent, regardless of ownership.”

“High Court Exceeded Its Revisional Jurisdiction by Re-evaluating Evidence”

The Supreme Court took strong exception to the High Court’s approach, declaring: “The High Court conducted a mini-trial on ownership, which is beyond the scope of revisional jurisdiction. The High Court ought to have confined itself to legality, jurisdictional error, or perversity — not factual scrutiny.”

The Court restored the order of the Rent Controller and allowed the appeal in full, reiterating that rent receipts are sufficient to sustain an eviction petition unless seriously rebutted — which was not the case here.

By reiterating that title is immaterial where tenancy is admitted or evidenced through rent receipts, the Supreme Court reaffirmed a key principle of tenancy jurisprudence. It held that rent control mechanisms cannot be derailed by attempts to raise ownership disputes, which lie outside the purview of the Rent Controller.

The judgment sends a strong message:
“Eviction proceedings under rent laws are to protect tenancy relationships, not determine property title — rent receipts remain central to that inquiry.”

Date of Decision: 09th September 2025