Reviewed case brief

Associated Hotels of India Ltd v RN Kapoor

AIR 1959 SC 1262

The determinative test for distinguishing a lease from a licence is exclusive possession. If the grantee has exclusive possession (right to exclude even the grantor), it is a lease regardless of the document's label.

property-lawleaselicenceexclusive-possessionsection-105
Court
Supreme Court of India
Year
1959
Subjects
Property Law
Reviewed
2026-06-30

Rule established

Test for lease vs licence is exclusive possession; document label is irrelevant

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        AIR 1959 SC 1262

        Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.