Nafiza Begaum vs. Srinivasan: Section 21(2)(a) Strikes Again in 2023

Four years after the TN Tenancy Act came into force, landlords in Chennai were still using Section 21(2)(a) to evict tenants who had failed to execute written agreements. The 2023 case of S. Nafiza Begaum vs. R. Srinivasan confirms that this eviction ground remains active — and relevant — in today's Tamil Nadu rental market.

What makes this case particularly notable is that it demonstrates a pattern. Section 21(2)(a) evictions are not rare edge cases — they are a recurring category of dispute flowing from the same root cause: tenancies that never got formalised in writing.

What Happened

In this 2023 case, the landlord filed an eviction petition after the tenant failed to enter into a written tenancy agreement as required under the TN Tenancy Act. The eviction petition was filed under Section 21(2)(a) — the provision that allows eviction specifically for this failure. The case proceeded through the Madras High Court.

The case adds to a body of 2022–2025 Madras HC judgments that uniformly confirm: the absence of a written tenancy agreement is a valid and sufficient ground for eviction in Tamil Nadu. Courts are not softening on this requirement. If anything, as the law matures, the standard is becoming stricter.

The Pattern Across Cases

Looking at cases from 2022 to 2025 — M. Vijayakumar, S.R. Venkatesh, S. Nafiza Begaum, and others — a clear pattern emerges: landlords who demand written agreements, face tenant refusal, and file under Section 21(2)(a) are consistently getting Rent Court access. The provision works. But the process still takes time. Prevention is faster than remedy.

The Faster Alternative

Instead of filing under Section 21(2)(a) and waiting for court resolution, landlords who ensure a registered rental agreement is signed at the start of the tenancy avoid this entire category of dispute. The agreement is the remedy — created before the problem arises, not after.

Related Cases

• Tenant Refused to Sign: M. Vijayakumar Case →
• Section 21(2)(a): Both Parties Failed to Sign →
• Ready to Sign, Still Evicted: The PrabhaKaran Case →