#Subsequent Events

Landlords cannot rely on a claimed bonafide requirement for eviction if the need is not genuine or if they later secure alternative premises or move abroad. The Delhi High Court set aside dismissal orders in three eviction cases, ruling that such subsequent events defeat the Section 25-B(8) defence. Tenants in similar disputes gain protection.

The Supreme Court clarifies that a landlord's bonafide need for eviction under rent control laws is fixed at the time of filing the suit. Later events - such as the death of the intended occupant or leasing out alternative premises - do not automatically extinguish this need unless they completely eclipse the original justification. This ruling reinforces legal certainty for landlords and requires courts to assess need prospectively, not retrospectively.

Karnataka High Court rules that pleadings can be amended under Order VI Rule 17 CPC to include subsequent events affecting possession, even after trial commencement, to prevent multiplicity of litigation and uphold substantive justice. The decision clarifies that procedural rigidity should not override equitable considerations in property disputes.