Punjab & Haryana High Court Fines Tenant ₹2 Lakh for Two-Year Delay in Vacating Premises
Court Says Undertakings Must Be Honoured Strictly and Without Casual Disregard
Tenant’s Wilful Default Undermines Faith in Judicial Orders, Rules Justice Sudeepti Sharma
By Our Legal Correspondent
New Delhi: December 09, 2025:
In a stern message against disregard for judicial orders, the Punjab and Haryana High Court have imposed ₹2 lakh exemplary costs on a tenant who delayed vacating premises for nearly two years despite giving a categorical undertaking to the Court. The ruling, delivered by Justice Sudeepti Sharma, underscores the principle that undertakings furnished before courts are binding commitments and failure to comply amounts to contempt.
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Background of the Case
- Tenant’s Undertaking: On January 19, 2023, the tenant assured the Court that he would vacate the disputed property by April 30, 2023.
- Actual Compliance: The tenant handed over possession only on September 5, 2025, almost two years after the deadline.
- Landlord’s Petition: The landlord was forced to file a contempt petition to enforce the undertaking.
- Court’s Finding: The High Court held that the tenant’s conduct was wilful, deliberate, and contemptuous.
Court’s Observations
Justice Sharma made strong remarks against the tenant’s conduct:
- Casualness Toward Law: The delay showed “casualness toward the majesty of law and undermined faith in judicial orders.”
- Undertaking Binding: An undertaking forms the basis of a judicial order and must be honoured strictly.
- Contempt Not Purged: Compliance after years of disregard does not erase contempt.
- Exemplary Costs: The Court imposed ₹2 lakh costs to deter similar conduct in future cases.
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Legal Issues Highlighted
The case raises important legal issues:
- Binding Nature of Undertakings: Undertakings given to courts are legally enforceable and equivalent to orders.
- Contempt of Court: Failure to comply amounts to contempt under the Contempt of Courts Act, 1971.
- Tenant-Landlord Disputes: Courts often rely on undertakings to settle eviction disputes; breach undermines judicial efficiency.
- Exemplary Costs: Courts can impose heavy costs to penalize wilful disobedience and discourage misuse of process.
Implications of the Judgment
The ruling has significant implications:
- For Tenants: Reinforces that undertakings must be honoured; delays can attract heavy penalties.
- For Landlords: Provides assurance that courts will enforce undertakings and penalize defaults.
- For Judiciary: Strengthens the authority of judicial orders and deters casual disregard.
- For Society: Sends a message that rule of law must be respected in property disputes.
Expert Views
Legal experts have welcomed the judgment:
- Property Lawyers: Say the ruling will deter tenants from misusing undertakings to delay eviction.
- Judicial Analysts: Stress that exemplary costs are necessary to uphold the dignity of courts.
- Landlord Associations: Call the judgment a relief for landlords facing prolonged litigation due to tenant defaults.
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Broader Context
Tenant-landlord disputes are among the most common civil cases in India. Courts often rely on undertakings to resolve eviction matters amicably. However, tenants sometimes misuse undertakings to delay compliance, forcing landlords into prolonged litigation.
This ruling adds to a growing body of jurisprudence emphasizing strict enforcement of undertakings and penalizing wilful defaults.
Conclusion
The Punjab and Haryana High Court’s decision to impose ₹2 lakh costs on a tenant for delaying compliance with his undertaking to vacate premises by nearly two years is a landmark ruling. It reinforces the principle that undertakings given to courts are binding commitments and failure to honour them amounts to contempt.
For tenants, the message is clear: respect your undertakings or face heavy penalties. For landlords, the ruling provides assurance that courts will enforce commitments and uphold the rule of law.
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