Summary and Analysis of H S Puttashankara vs Yashodamma 2025 INSC 1087

1. Heading of the Judgment

Case Name: H.S. Puttashankara vs Yashodamma
Citation: 2025 INSC 1087
Court: Supreme Court of India
Judges: Hon'ble Mr. Justice J.K. Maheshwari and Hon'ble Mr. Justice Vijay Bishnoi
Nature of Case: Civil Appeal arising from a Special Leave Petition (SLP (C) No. 15565 of 2021)

Citation: H.S. Puttashankara vs Yashodamma, 2025 INSC 1087 (Supreme Court of India, decided on September 09, 2025)

2. Related Laws and Sections

The judgment primarily interprets and applies the Karnataka Rent Act, 1999. The key sections central to this dispute are:

• Section 27: This is the main section that allows a landlord to file for eviction of a tenant on specified grounds. The appellant filed the eviction petition under clauses (2)(a), (e), (g), and (o) of this section.

• Section 3(e): This defines who a "landlord" is. Crucially, it includes not just the absolute owner but also any person who is receiving or is entitled to receive rent, including a trustee, guardian, or receiver.

• Section 43: This is the most critical section in this judgment. It provides the procedure a Rent Controller must follow when a tenant denies the very existence of a landlord-tenant relationship.

3. Basic Judgment Details

• Appellant (Landlord): H.S. Puttashankara

• Respondent (Tenant): Yashodamma

• Subject Property: Property No. 7, 26th Cross, Cuban Pet, Bengaluru - 560002.

• Lower Courts:
  Rent Controller (Court of Small Causes, Bangalore): Allowed the eviction petition, directing the tenant to vacate the property.
  High Court of Karnataka: Allowed the tenant's revision petition and set aside the Rent Controller's order, effectively dismissing the eviction case.

• Supreme Court's Decision: Allowed the landlord's appeal, set aside the High Court's order, and restored the eviction order passed by the Rent Controller.

4. Explanation of the Judgment

Core Legal Issue

The central question before the Supreme Court was whether a valid jural relationship of landlord and tenant existed between Mr. H.S. Puttashankara and Ms. Yashodamma. The tenant had disputed this relationship and also challenged the landlord's title over the property.

Background Facts

The appellant, H.S. Puttashankara, claimed that the suit property originally belonged to his great-grandfather, Sri Banappa. It devolved to his legal heirs, who executed a Release Deed in 2015 in his favour, making him the owner. The respondent, Yashodamma, was the daughter and legal heir of the original tenant, Mysore Lingamma. A previous eviction petition filed by the appellant's father against the respondent's mother had established that a landlord-tenant relationship existed at that time.

The respondent, however, claimed there was no relationship with the appellant. She argued the property actually belonged to the "Ankalappa Mutt" and that Sri Banappa was merely a trustee. She contended that the appellant could not prove his lineage from Sri Banappa and therefore had no title or right to seek eviction.

The Supreme Court's Analysis and Reasoning

The Supreme Court's decision focused on the correct interpretation of Section 43 of the Karnataka Rent Act, 1999. The Court provided an in-depth analysis of this provision:

1. Procedure under Section 43: The Court clarified that when a tenant denies the landlord-tenant relationship, the Rent Controller's first duty is to look for:
   A lease document, or if that is not available,
   A receipt or acknowledgment of rent purportedly signed by the landlord.

2. Prima Facie Evidence: If such a document is produced, the law mandates that the Court must accept it as prima facie evidence (evidence sufficient to establish a fact unless disproved) of the relationship. The Rent Controller can then proceed to hear the eviction case on its merits.

3. When must the Rent Controller stop? The proceedings must be halted and the parties sent to a civil court only if:
   The lease is oral, the relationship is denied, and no rent receipt is produced, or
   The Court has reasons to suspect the genuineness of the lease document or rent receipt.

4. Application to the Present Case: The appellant-landlord had produced original rent receipts (specifically one dated 20.07.2015 for rent from 2013-2014) that he had issued to the respondent. The Supreme Court held that this successfully discharged the "initial burden" placed on the landlord by Section 43. Therefore, the Rent Controller was absolutely correct in proceeding with the hearing and deciding the case.

Error by the High Court

The Supreme Court found that the High Court committed a legal error in its revisional jurisdiction:

• Exceeding Jurisdiction: The High Court ventured into a fact-finding mission, which is not permitted in revision. It questioned the appellant's lineage and his relationship with the original owner, Sri Banappa, which were matters related to title.

• Misapplying the Law: The High Court failed to appreciate that the Rent Controller's domain under the Rent Act is limited to establishing the landlord-tenant relationship through the documents mentioned in Section 43, not to adjudicate on the absolute title of the property. By focusing on the title dispute and the denial of signatures by the respondent's son (which was a matter of evidence to be tested by the Rent Controller), the High Court misplaced its focus.

Supreme Court's Directions and Conclusion

The Supreme Court held that the High Court's impugned order was unsustainable in law. It underlined that once the rent receipts were produced, the mandate of Section 43 was fulfilled, and the Rent Controller was empowered to continue.

Final Decision: The Supreme Court:

• Allowed the appeal filed by the landlord, H.S. Puttashankara.

• Set aside the judgment of the High Court of Karnataka.

• Restored the eviction order dated 01.09.2017 passed by the Rent Controller, which had directed the respondent, Yashodamma, to vacate the premises.