M/S Unichem Laboratories Ltd. v. Rani Devi & Anr.
Background
Unichem Laboratories, a company with an industrial unit in Ghaziabad, had been allotted workers' quarters by the U.P. State Government under the Uttar Pradesh Industrial Housing Act, 1955, and had in turn allotted one such quarter to an employee, Dharam Dev Yadav. After Yadav retired in 1992 and was given a further six months to vacate, he did not leave, and after his death his widow and family (the respondents) continued living there. The company sued for eviction and damages; the trial court decreed eviction, but the High Court reversed, holding the company itself had no standing to sue and that only the State or the Labour Commissioner could.
Decision Breakdown
The Supreme Court held that the civil court did have jurisdiction to try the eviction suit, since the provision that had earlier vested eviction powers exclusively in the Labour Commissioner (Section 21) had been deleted from the Act in 1972, restoring ordinary civil jurisdiction under Section 9 CPC. It further held that the undisputed facts, the State's allotment to the company, the company's sub-allotment to its worker, and the employer-employee relationship, were enough to establish a tenancy-like contractual relationship giving the company standing to sue for eviction. Since the employee's right to occupy was tied to his employment, his tenancy ended on retirement, and his widow/family had no independent right to continue in occupation. The Court set aside the High Court's order, restored the trial court's eviction decree, and gave the occupants three months to vacate on depositing the decreed amount and arrears.
Lesson Learnt
An employer who provides staff housing as part of employment can itself sue to evict a former employee's family once the employment (and the tenancy tied to it) ends: the right to occupy such housing does not survive the employee's retirement or death.