Failure to execute a written tenancy agreement attracts eviction under Section 21(2)(a).

The respondents sought eviction under Section 21(2)(a) of the Tamil Nadu Regulation of Rights and Responsibilities of Landlords and Tenants Act, 2017, claiming they had purchased the premises previously tenanted by the petitioner’s father-in-law.

The petitioner disputed the landlord–tenant relationship, alleging no attornment or notice, and relied on her rent deposits pursuant to an earlier court order.

The Rent Controller allowed the eviction petition, finding the respondents were the landlords, the termination notice had been validly served despite being returned “unclaimed,” and no valid rental agreement existed.

The Rent Control Appellate Authority affirmed, and the petitioner challenged that decision under Article 227 of the Constitution.

Whether the concurrent findings that the respondents were the petitioner’s landlords, and that the termination notice was validly served, warranted interference in revision.

Whether the absence of a valid written rental agreement attracted eviction under Section 21(2)(a) of the 2017 Act, as held by the authorities below.

Whether the concurrent orders disclosed a legal or evidentiary error sufficient to justify revisional interference.

The Court applied the restricted revisional-review standard it associated with Section 25 of the Tamil Nadu Buildings (Lease and Rent Control) Act, notwithstanding that the petition was under Article 227 and the eviction proceeding arose under the 2017 Act.

Under that standard, revision is not an appeal or an occasion to reappreciate evidence; interference may be warranted where findings are contrary to law, perverse, unsupported by evidence, reached without considering material evidence, or result in a miscarriage of justice.

The Court referred to Ramdoss v. K. Thangavelu, V.M. Mohan v. Prabha Rajan Dwarka, Rukminiamma Saradamma v. Kallyani Sulochana, and Hindustan Petroleum Corporation Ltd. v. Dilbahar Singh on revisional limits.

The Court relied on Priyanka Kumari v. Shailendra Kumar for treating a notice sent to the premises and returned “unclaimed” as validly served.

The Court accepted the authorities’ application of Section 21(2)(a) of the 2017 Act to the absence of a valid rental agreement.

The Court found that the respondents’ sale deeds established their ownership of the subject premises and that the petitioner’s predecessor had recognized the former owner as landlord; it therefore upheld the finding of a landlord–tenant relationship and rejected the denial of the respondents’ title as mala fide.

The termination notice had been sent to the premises and returned “unclaimed,” which the Court treated as valid service under the cited precedent.

It further noted the authorities’ finding that no valid rental agreement existed and their conclusion that Section 21(2)(a) applied.

Applying the limited revisional standard, the Court found no perversity, legal error, or other basis to disturb the concurrent findings.

It directed the petitioner to vacate and deliver vacant possession within two months from 30 September 2026; there was no order as to costs, and the connected miscellaneous petition was also dismissed.