surrender of possession transforms lease disputes into pure monetary claims that fall outside exclusive statutory tenancy protections

When a licensee or tenant voluntarily hands over vacant peaceful possession of premises to the licensor, the character of the dispute fundamentally shifts from an action for recovery of immovable property to a pure monetary claim in personam concerning security deposits or contractual dues. Statutory bars in special tenancy enactments designed to protect physical occupancy do not operate to neutralize arbitration agreements when possession is no longer in dispute. Such monetary claims represent independent contractual rights in personam that can be validly adjudicated by an arbitral tribunal pursuant to the agreed arbitration clause. (Motilal Oswal Financial Services Limited v. Santosh Cordeiro and Another | 2026 INSC 5)