In a significant ruling that drew a packed courtroom on Friday, the Supreme Court finally settled a dispute that had confused courts for years. At the heart of the matter was a simple but powerful question: Can old tenants of government-owned corporations claim protection under State rent laws, or must they face eviction under the stricter Public Premises Act (PP Act), 1971? The bench, led by Justice N.V. Anjaria, delivered a detailed judgment, overturning the earlier two-judge ruling in Suhas H. Pophale and restoring full authority to the PP Act.
Background
The case arose from a long-standing property dispute between the Life Insurance Corporation of India (LIC) and Vita Pvt. Ltd., a tenant inducted way back in 1957 into a Mumbai flat owned by LIC. When LIC terminated the tenancy and initiated eviction under the PP Act, the Bombay High Court stepped in and quashed the eviction, relying heavily on Suhas H. Pophale, which had ruled that tenants occupying premises before 16 September 1958 were protected by State Rent Acts.
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That earlier judgment created a legal maze. It carved tenants into two groups—those inducted before 1958 and those after-holding that the PP Act applied only to the latter. This meant that thousands of tenants of LIC, nationalised banks, and government corporations stood shielded from the PP Act simply due to the date of their entry. The Supreme Court found this reasoning fundamentally inconsistent with earlier Constitution Bench law.
Court’s Observations
The bench took a firm tone, noting that Suhas H. Pophale had “overlooked, ignored and disregarded” binding rulings of larger benches. “The two-Judge Bench… could not have taken a view contrary to the decisions of larger benches,” the court remarked, calling it a breach of judicial discipline.
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The Court revisited its landmark 1990 Constitution Bench ruling in Ashoka Marketing, which had already held that both the PP Act and Rent Control Acts are special laws-but the PP Act must prevail because it is later in time and intended to ensure speedy eviction of unauthorised occupants from public property.
In a candid moment during dictation, the bench observed, “The Public Premises Act is meant to protect public property, not to create indefinite tenancies merely because a private landlord became a government corporation later.” That line captured the Court's frustration with the loophole created over the years.
The bench pointed out another flaw: Suhas H. Pophale had artificially read Section 2(g) of the PP Act to create “vested rights” for pre-1958 tenants, a reading the Court said had no support in the statutory scheme. What matters, the bench clarified, is not when the tenant entered the property, but whether the premises are public premises at the time eviction is sought.
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“The factum of occupation at the material time is sufficient,” the Court reiterated, reaffirming a 1980 three-judge ruling in Jain Ink.
Decision
Bringing the long-running debate to rest, the Court held:
- Suhas H. Pophale is incorrect, unjustified, and does not hold the field.
- The PP Act overrides all State Rent Control legislations, regardless of when the tenancy began.
- Tenants of LIC, nationalised banks, and government corporations cannot claim immunity from eviction under State rent laws merely due to historic occupation.
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With this, the Court restored complete legal clarity: public property must be governed by the PP Act alone whenever eviction is sought.
The order concludes with the Court reiterating the binding authority of larger bench judgments and setting aside all contrary interpretations.
Case Title: Life Insurance Corporation of India & Anr. vs. Vita Pvt. Ltd. & Others
Case No.: Civil Appeal No. 2638 of 2023 (with connected appeals)
Case Type: Civil Appeal – Interpretation of Public Premises Act vs State Rent Control Laws
Decision Date: 2025 (as per judgment header: 2025 INSC 1419)
