Justice Neena Bansal Krishna of the Delhi High Court has ruled that the payment of ‘pagri’ by a tenant does not render a tenancy non-terminable, upholding an eviction decree in favour of landlady Smt. Mithlesh Devi.

The decision, reported on June 18 and 19, 2026, clarifies that substantial upfront payments do not alter the fundamental landlord-tenant relationship or prevent owners from seeking possession of their property. The court dismissed an appeal filed by M/S Shyam Lal & Sons, a tenant occupying a commercial shop in the Nawada area of New Delhi.

The dispute involved a shop let out under a rent agreement dated January 1, 2001. M/S Shyam Lal & Sons argued that a Memorandum of Understanding (MoU) executed alongside the agreement changed the nature of their occupancy. They claimed that the payment of Rs. 1.

Does the payment of pagri grant a tenant ownership rights in India?

No, the Delhi High Court has clarified that pagri is an upfront premium for tenancy rights and does not make a tenant a co-owner or grant a non-terminable interest in the property.

Can a tenant be evicted if they paid a large pagri amount?

Yes, as long as the landlord follows the due process of law. The court found that even if the pagri amount was nearly 75% of the property’s market value, it does not prevent the landlord from seeking eviction.

Is a separate notice to quit required before filing an eviction suit?

The court noted that the filing of an eviction suit itself serves as sufficient notice to the tenant to vacate the premises, relying on established legal precedents in India.