In a significant ruling on landlord–tenant disputes, the Supreme Court on Tuesday restored an eviction order passed by a Bengaluru Rent Controller, overturning a Karnataka High Court decision that had earlier sided with the tenant. The case revolved around property ownership, rental receipts, and the question of who truly stood as landlord under the Karnataka Rent Act, 1999.
Background
The dispute concerns a property at 26th Cross, Cubbonpet, Bengaluru. The appellant, H.S. Puttashankara, claimed ownership through a release deed executed in his favour in 2015 by his relatives. He argued that the respondent, Yashodamma, was a tenant, having inherited the tenancy from her late mother, Mysore Lingamma.
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Lingamma, decades earlier, had admitted before the Rent Controller that she paid rent to the appellant’s father, which established the landlord–tenant link. Relying on this and rent receipts issued as recently as 2015, the appellant sought eviction.
However, the High Court in 2021 disagreed. It reasoned that Puttashankara failed to prove his lineage from the original owner, Sri Banappa, and that the signatures on the rent receipts were disputed. The HC concluded no landlord–tenant relationship existed and set aside the Rent Controller’s eviction order.
Court’s Observations
Hearing the appeal, the Supreme Court bench led by Justice J.K. Maheshwari delved into Section 43 of the Karnataka Rent Act, 1999, which governs how courts must handle disputes over landlord–tenant relationships.
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The bench explained:
“Once rent receipts acknowledging payment are produced, they stand as prima facie proof of the relationship. The Rent Controller can then proceed with the case, without stepping into questions of property title.”
The Court criticized the High Court for venturing into factual inquiries and lineage disputes, which, it said, were outside the scope of revisional powers in rent matters. “The High Court, in its own wisdom, misdirected itself,” the bench remarked, noting that title disputes should be dealt with separately in civil courts, not in eviction proceedings.
The justices stressed that the Rent Controller had correctly relied on the rent receipts, which discharged the landlord’s initial burden of proof. By contrast, the High Court had been “swayed by denial of signatures” and overlooked the statutory framework.
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Decision
Concluding that the High Court erred in law, the Supreme Court set aside its order and restored the Rent Controller’s eviction directive against Yashodamma. With this, the long-running dispute tilted back in favour of the landlord, reaffirming the limited scope of revisional powers in rent cases.
The Court allowed the appeal and dismissed any pending applications.
Case: H.S. Puttashankara v. Yashodamma
Date of Judgment: 9 September 2025
