H.S. Puttashankara vs Yashodamma 2025 INSC 1087 - Karnataka Rent Act - Existence Of Landlord-Tenant Relationship

Karnataka Rent Act, 1999 - Section 43- Whenever there is a dispute with respect to existence of landlord-tenant relationship, it shall be lawful for the Court to accept the document of the lease and in absence thereof, a receipt of acknowledgment of payment of rent purported to be signed by the landlord as prima-facie evidence of relationship and proceed to hear the case- Whenever a dispute arises as to the jural relationship between the parties, the Court has to examine lease agreement or in its absence, receipts acknowledging payment of rent signed by the landlord as prima-facie proof of such relationship and proceed with the hearing of the case. In case the existence or genuineness of these documents are put to question, or where the lease is oral and the parties deny the relationship, or there are reasons for Court to suspect the genuineness of the documents of either lease or receipt or acknowledgment of payment of rent, the proceedings shall to be halted and the parties be referred to a competent civil Court- Only in case where the lease is oral in nature and party denies the jural relationship and no receipt or acknowledgement of payment of rent is produced, or the Court suspects the genuineness of the documents, the Court is bound to stop further proceedings and refer the parties before the competent Court for adjudication of their title, which implies that Rent Controller was not empowered to adjudicate the dispute related to title between the parties. (Para 6-10)