As per case facts, the Landlord (Sarwan Singh) filed an eviction petition under Section 13-B of the East Punjab Urban Rent Restriction Act, 1949, against the tenant, asserting Non-Resident Indian ... (NRI) status and a bona fide need for the shop. The Rent Controller dismissed the petition, citing the absence of the original passport to prove NRI status and disbelieving the genuineness of the need, noting the landlord worked as a farm labour in England. The landlord appealed to the High Court, also seeking to introduce the original passport as additional evidence. The landlord died during proceedings, and his legal representatives continued the case. The question arose whether the Rent Controller correctly dismissed the eviction petition, especially regarding the proof of NRI status and the genuineness of the landlord's bona fide need, given the summary nature of proceedings under Section 13-B and other available evidence. Finally, the High Court found that the Rent Controller erred by non-suiting the landlord merely for non-production of the original passport when an attested copy was tendered and other evidence (Special Power of Attorney) supported NRI status. The Court emphasized the summary nature of such proceedings and the strong presumption of bona fide need for NRI landlords, which the tenant failed to rebut. The Court also held that working as a farm labour in England does not negate the bona fide need. The High Court allowed the revision petition, confirming the landlord's NRI status and bona fide need.