Colaco v New Theatres Limited (Civil Appeal No. 11 of 1955)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Court held that the magistrate properly exercised discretion in granting a seven-month tenancy. Benefit to the public is a relevant factor under section 11(1) when assessing reasonableness. The Ordinance does not presume that new tenancies will normally run for the full two years—the period lies entirely within the magistrate's discretion. An appellate court cannot interfere with the weight attached to evidence, and where some evidence supports the magistrate's findings, the Court will not interfere on a question of fact, as appeals under section 13(1) are limited to questions of law.
Outcome
Appeal dismissed; magistrate's order granting seven-month tenancy upheld
Facts
The appellant had rented bar premises within the respondent's Playhouse Cinema in Nairobi. The respondent terminated the lease by notice to quit on 31 May 1954, which expired 31 October 1954. Protection under the Increase of Rent (Restriction) Ordinance 1949 ceased 24 December 1954 when the Landlord and Tenant (Shops and Hotels) (Temporary Provisions) Ordinance 1954 came into force. The appellant applied for a new tenancy under section 10 of the 1954 Ordinance. The magistrate sat with two assessors who advised tenancies of 24 and 12 months respectively. The magistrate, exercising his discretion not to follow the assessors' advice, ordered a new tenancy until 31 July 1955—approximately seven months—on the ground that the respondent would provide better service to the public by running the cinema and bar as a joint concern under unified management. The appellant operated another bar elsewhere. By consent, rent and other terms were determined later.
Issues
- Whether benefit to the public is a relevant factor when exercising discretion to grant a new tenancy under section 11(1) of the Landlord and Tenant (Shops and Hotels) (Temporary Provisions) Ordinance 1954.
- Whether the Ordinance intends that a new tenancy should normally be for the full two-year period.
- Whether an appellate court can interfere with the weight attached by the magistrate to particular factors.
- Whether the magistrate erred in law by determining the period of tenancy before fixing rent and other terms.
Orders
- Appeal dismissed.
- Costs awarded to the respondent.
Rules and key headnotes
Legislation cited (8)
- Landlord and Tenant (Shops and Hotels) (Temporary Provisions) Ordinance 1954 s.11(1)
- Landlord and Tenant (Shops and Hotels) (Temporary Provisions) Ordinance 1954 s.13(1)
- Landlord and Tenant (Shops and Hotels) (Temporary Provisions) Ordinance 1954 s.10
- Landlord and Tenant (Shops and Hotels) (Temporary Provisions) Ordinance 1954 s.11(3)
- Landlord and Tenant (Shops and Hotels) (Temporary Provisions) Rules 1954 r.11
- Landlord and Tenant (Shops and Hotels) (Temporary Provisions) Rules 1954 r.14
- Landlord and Tenant (Shops and Hotels) (Temporary Provisions) Rules 1954 r.9
- Increase of Rent (Restriction) Ordinance 1949
Cases cited (2)
- Cumming v Danson [1942] 2 All ER 653 (CA)
- Cresswell v Hodgson [1951] 2 KB 92 (CA)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.