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
Recommended Citation
"Jagram v. Dadwah" (2026). All Decisions. 2474.
https://ir.lawnet.fordham.edu/housing_court_all/2474
