KAMLA DEVI vs LAXMI DEVI — C.A. No. 1822/1998

Summary: The Supreme Court held that the suit plot (9x7 open land) does not constitute "premises" under Section 2(i) of the Delhi Rent Control Act, 1958, and therefore Section 50 barring civil court jurisdiction does not apply. The Court found that although a latrine structure existed on the plot, the compromise agreement clearly showed that only the open land—for which Rs.5 monthly rent was agreed—was let out. Since the tenant alone owned the unauthorized structure and the landlord acquired no rights in it, the subject matter of tenancy was bare land, not a building or structure, making the suit for eviction maintainable and allowing the landlord's appeal. This case analysis is maintained by casestatus.in based on publicly available court records.