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As per case facts, the plaintiff-landlord initiated a suit for eviction against the defendant-tenant under the M.P. Accommodation Control Act, 1961, citing bona fide requirement for opening a showroom. Both
...the trial court and the lower appellate court found in favor of the plaintiff, confirming the bona fide need and lack of other suitable premises. However, the High Court reversed these judgments in a second appeal, reasoning that the lower courts had wrongly placed the onus of proof regarding alternative accommodation on the defendant and had ignored the plaintiff's admission of possessing other shops without justifying their unsuitability. The plaintiff appealed, arguing the High Court improperly re-evaluated evidence in a second appeal. The question arose whether the High Court was justified in setting aside concurrent findings of fact by re-appreciating evidence and if the lower courts correctly assessed the landlord's bona fide requirement, particularly concerning alternative accommodation. Finally, the Supreme Court ruled that the High Court erred in law by re-appreciating the evidence and overturning concurrent findings of fact in a second appeal, as this is permissible only if the findings were vitiated by non-consideration of relevant evidence or an erroneous approach. The Supreme Court emphasized that a landlord is the best judge of their own business requirement, finding no such flaws in the lower court's decisions. Consequently, the High Court's judgment was set aside, and the original judgments favoring the landlord were restored.
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