Life Insurance Corporation Of India vs M.S.Jain

insc-2025-1419 Supreme Court of India 11 December 2025 • 43 min read

10 cases cited (0 SG, 10 foreign) Cited by 1 case

Practice Areas

Act cannot invoke the protection of the Rent Control Act Acts namely the Life Insurance Corporation Act, 1956 Although in both the Public Premises Act, 1971 As a result of the enactment of the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970 Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970 Banking Companies Act, 1970 Board of Trustees or any successor company constituted under or referred to in the Major Port Trusts Act, 1963 Bombay Rent Control Act, 1947 Cantonment Board constituted under the Cantonments Act, 1924 Companies Act, 2013 Constitution of India Constitutionality of the PP Act, 1971 Corporation established under the provisions of the Life Insurance Corporation Act, 1956 Corporations or Companies to proceed against them under the PP Act, 1971 Court ruled that the PP Act, 1971 Court was whether the provisions of the PP Act, 1971 Delhi Municipal Corporation Act, 1957 Delhi Rent Control Act Delhi Rent Control Act unless it can be said that the PP Act, 1971 Delhi Rent Control Act, 1958 Enemy Property Act, 1968 Eviction proceedings were successfully initiated under the PP Act, 1971 Explaining the operational status of the Rent Control legislation and the PP Act, 1971 Framework of Public Premises Act, 1971 Holding that the premises was governed by the PP Act, 1971 In a situation where neither the PP Act, 1971 Industrial Disputes Act, 1947 Institute incorporated by the Institutes of Technology Act, 1961 Invocation and applicability of the provisions of the PP Act, 1971 It became entitled to resort to the provisions of Public Premises Act, 1971 It was incorrect on part of the High Court to hold that the provisions of the PP Act, 1971 It was stated that the consequence of giving overriding effect to the provisions of the PP Act, 1971 It was thus clearly expressed that the PP Act, 1971 LIC to file an application with the Estate Officer under the PP Act, 1971 LIC would become public premises within the meaning of the PP Act, 1971 Life Insurance Corporation Act, 1956 Lodging House Rates Control Act, 1947 Maharashtra Rent Control Act, 1999 Metro Railway (Operation and Maintenance) Act, 2002 Negating the contention that the provisions of the PP Act, 1971 New Delhi Municipal Council Act, 1994 PP Act 1971 Presidency Small Cause Courts Act, 1882 Public Premises (Eviction of Unauthorised Occupants) Amendment Act, 1980 Public Premises Act, 1971 Public Premises prior to coming into force of the PP Act, 1971 Punjab Reorganisation Act, 1966 Rent Control Act and no exception could be created on the basis of the date of coming into force of the PP Act, 1971 Rent Control Act and the PP Act, 1971 Rent Control Act and the Public Premises Act, 1971 Rent Control Act to contend that the PP Act, 1971 State Rent Legislation remained beyond the application of Public Premises Act, 1971 State Rent legislation and shall remain beyond the application of the PP Act, 1971 Transfer of Property Act, 1882 consequence of giving overriding effect to the provisions of the Public Premises Act, 1971 issue of overriding effect of the PP Act, 1971 life insurance business was nationalized under the Life Insurance Corporation Act, 1956 mere fact that by virtue of a fiction the Public Premises Act, 1971 principal question that arises for determination in this batch of matters is whether the provisions of the PP Act, 1971 prospectivity and application of the PP Act, 1971 provisions of PP Act, 1971 provisions of the PP Act, 1971 statutory machinery envisaged under the PP Act, 1971 tenant could not be evicted by giving retrospective application to the provisions of the PP Act, 1971

Judges (3)

N.V. Anjaria Delivered Sandeep Mehta Coram Vikram Nath Coram

Parties (2)

Life Insurance Corporation of India Appellant Vita Respondent

Case Significance

Life Insurance Corporation Of India vs M.S.Jain is a Supreme Court of India decision dated December 11, 2025 (citation: insc-2025-1419). Three-judge bench reference resolving conflicting views on whether the Public Premises (Eviction of Unauthorised Occupants) Act, 1971 overrides State Rent Control Legislations. The Supreme Court held the PP Act has overriding applicability for recovery of possession of public premises by government entities, overruled the contrary propositions in Suhas H. Pophale, and clarified that tenancy termination by notice under the Transfer of Property Act renders occupation unauthorised. The bench comprised Justices N.V. Anjaria, Sandeep Mehta and Vikram Nath. The judgment was delivered by Justice N.V. Anjaria.

This case has been cited by 1 subsequent judgment. The judgment references 10 case citations.

Summary

Three-judge bench reference resolving conflicting views on whether the Public Premises (Eviction of Unauthorised Occupants) Act, 1971 overrides State Rent Control Legislations. The Supreme Court held the PP Act has overriding applicability for recovery of possession of public premises by government entities, overruled the contrary propositions in Suhas H. Pophale, and clarified that tenancy termination by notice under the Transfer of Property Act renders occupation unauthorised.

What was the outcome of Life Insurance Corporation Of India vs M.S.Jain?

Three-judge bench reference resolving conflicting views on whether the Public Premises (Eviction of Unauthorised Occupants) Act, 1971 overrides State Rent Control Legislations. The Supreme Court held ...

Statutes Cited

Act cannot invoke the protection of the Rent Control Act

s 2(e)

Acts namely the Life Insurance Corporation Act, 1956

Although in both the Public Premises Act, 1971

As a result of the enactment of the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970

Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970

Banking Companies Act, 1970

Board of Trustees or any successor company constituted under or referred to in the Major Port Trusts Act, 1963

Bombay Rent Control Act, 1947

Cantonment Board constituted under the Cantonments Act, 1924

Companies Act, 2013

consequence of giving overriding effect to the provisions of the Public Premises Act, 1971

Constitution of India

Constitutionality of the PP Act, 1971

Corporation established under the provisions of the Life Insurance Corporation Act, 1956

Corporations or Companies to proceed against them under the PP Act, 1971

Court ruled that the PP Act, 1971

Court was whether the provisions of the PP Act, 1971

Delhi Municipal Corporation Act, 1957

s 3

Delhi Rent Control Act

s 39(2)

Delhi Rent Control Act unless it can be said that the PP Act, 1971

Delhi Rent Control Act, 1958

Enemy Property Act, 1968

s 2

Eviction proceedings were successfully initiated under the PP Act, 1971

Explaining the operational status of the Rent Control legislation and the PP Act, 1971

Framework of Public Premises Act, 1971

Holding that the premises was governed by the PP Act, 1971

In a situation where neither the PP Act, 1971

Industrial Disputes Act, 1947

Institute incorporated by the Institutes of Technology Act, 1961

Invocation and applicability of the provisions of the PP Act, 1971

issue of overriding effect of the PP Act, 1971

It became entitled to resort to the provisions of Public Premises Act, 1971

It was incorrect on part of the High Court to hold that the provisions of the PP Act, 1971

It was stated that the consequence of giving overriding effect to the provisions of the PP Act, 1971

It was thus clearly expressed that the PP Act, 1971

LIC to file an application with the Estate Officer under the PP Act, 1971

LIC would become public premises within the meaning of the PP Act, 1971

life insurance business was nationalized under the Life Insurance Corporation Act, 1956

Life Insurance Corporation Act, 1956

Lodging House Rates Control Act, 1947

Maharashtra Rent Control Act, 1999

s 33

mere fact that by virtue of a fiction the Public Premises Act, 1971

Metro Railway (Operation and Maintenance) Act, 2002

Negating the contention that the provisions of the PP Act, 1971

New Delhi Municipal Council Act, 1994

s 2

PP Act 1971

s 2(e) s 2(g) s 5 s 9

Presidency Small Cause Courts Act, 1882

s 41

principal question that arises for determination in this batch of matters is whether the provisions of the PP Act, 1971

prospectivity and application of the PP Act, 1971

provisions of PP Act, 1971

provisions of the PP Act, 1971

Public Premises (Eviction of Unauthorised Occupants) Amendment Act, 1980

Public Premises Act, 1971

s 15 s 2(e)

Public Premises prior to coming into force of the PP Act, 1971

Punjab Reorganisation Act, 1966

s 79

Rent Control Act and no exception could be created on the basis of the date of coming into force of the PP Act, 1971

Rent Control Act and the PP Act, 1971

Rent Control Act and the Public Premises Act, 1971

Rent Control Act to contend that the PP Act, 1971

State Rent legislation and shall remain beyond the application of the PP Act, 1971

State Rent Legislation remained beyond the application of Public Premises Act, 1971

statutory machinery envisaged under the PP Act, 1971

tenant could not be evicted by giving retrospective application to the provisions of the PP Act, 1971

Transfer of Property Act, 1882

Cases Cited (10)

IN (10)

(1974) 2 SCC 365 (1978) 2 SCC 213 (1980) 4 SCC 435 (1990) 4 SCC 406 (1996) 8 SCC 489 (1997) 6 SCC 723 (1997) 8 SCC 767 (2002) 8 SCC 182 2025 INSC 1419 AIR 1956 SC 614

Cited By (1)

Life Insurance Corporation Of India vs M.S.Jain

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (insc-2025-1419)