Case Type

Holdover-Lease Expiration

Housing Type

Market Rate

Court

Civil Court of the City of New York

County

Queens County (Queens)

L&T / Index / Case / Docket / Clerk's Number

LT-304878-26/QU

Slip Opinion Number

2026 NY Slip Op 32225(U)

Petitioner

Khemkaran Jagram

Respondent

Ronson Dadwah; John Doe; Jane Doe

Judge

Guthrie, Clinton J.

Decision/Order Date

2026-09-10

Posture

Pre-Answer Motion by Landlord

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

RPL §231-c requires a GCEL notice to accompany any RPL §226-c termination notice — either annexed or folded into it. Landlord served the GCEL notice separately; the 90-day notice to quit went out without it. Court dismisses the petition on that unamendable defect. Court separately clarifies that, post-HSTPA, a notice of termination need not expire on the last day of the tenancy term. Dismissal is without prejudice.

Keywords

GCEL; Petition Dismissed for Failure to Attach GCEL Notice Under RPL § 231-c to the Predicate Notice; Since 2019 HSTPA Amendments Landlords No Longer Required to Have Notice of Termination Under RPL § 232-a Expire on Same Day as Term of Lease or Tenancy Expires

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