Himachal Pradesh High Court: Agreement to Sell Doesn’t End Landlord-Tenant Relationship

The Himachal Pradesh High Court held that a landlord-tenant relationship does not end merely because an agreement to sell includes an option to sell or lease the property.

Relying on Section 54 of the Transfer of Property Act, 1882, the Court observed that such an agreement does not itself create any interest in the property. 

The ruling came in a rent petition where the landlord sought eviction for non-payment of rent. The tenant’s son argued that an agreement to sell had already been executed in his favour, but the Court rejected this contention.

[Prem Mohini Gupta v Sumitra (Deceased through LRs)]