Yes, a landlord can evict a tenant on the grounds of bona fide personal requirement under the relevant Rent Control Act, but this must be a genuine and reasonable need, not a mere desire. The landlord needs to prove that the tenant needs the premises for their own use or for the use of their family and that this need is real and not just a pretext for getting rid of the tenant.
What constitutes bona fide need?
Genuine Requirement:
The landlord's need must be real and not a sham or a mere desire to get the property vacated.
Need of the Landlord or Family:
The need can be for the landlord themselves, their spouse, children, or other dependents.
Substantiated with Evidence:
The landlord needs to provide evidence to support their claim of a bona fide need.
Not a Mere Whim or Desire:
The need must be more than just a passing thought or a wish to have the property vacant.
Consideration of Alternative Accommodation:
The court may consider if the landlord has other suitable accommodation that could fulfill the same need.
Practical Approach:
The concept of bona fide need should be applied with a practical approach, considering the realities of life.
Examples of Bona Fide Needs:
Personal Residence:
The landlord may require the property for themselves or their family to live in.
Starting a Business:
If the landlord wants to start a business and needs the premises for that purpose.
Medical Needs:
The landlord or a family member may need the premises for medical treatment.
Education:
If the landlord or a family member needs the premises for education.
In conclusion, the landlord must prove a genuine and reasonable need for the property, supported by evidence, to successfully evict a tenant on the grounds of bona fide personal requirement.

A bench of Justice Pankaj Mithal and Justice N Kotiswar Singh laid down the law on “bonafide requirement” for eviction of tenants under the Rent Control Act.
The Supreme Court held this in the case of Kanhaiya Lal Arya v. Md. Ehsan & Ors. (2025).

What is the Provision for Eviction Under the Rent Control Act?
Section 19 of the Jharkhand Building (Lease, Rent & Eviction) Control Act, 2011 provides for tenant eviction.
A tenant cannot be evicted except by the Controller's order, despite any contrary contract or law.
Valid grounds for eviction include:
Breach of tenancy conditions
Unauthorized subletting
Ceasing employment (if occupying as an employee)
Material deterioration of the building due to the tenant's negligence
Landlord reasonably requiring building for personal/beneficiary occupation (Bonafide Requirement)
The controller may allow partial eviction if:
A reasonable requirement can be satisfied by partial eviction
Tenant agrees to this arrangement
Standard rent will be proportionately fixed for the remaining portion
Important clarifications:
"Landlord" does not include agents
When multiple buildings are involved, the landlord has the right to choose which building they prefer, and tenants cannot challenge this preference
These provisions are subject to the Industrial Disputes Act, 1947, and Section 31.