The correct answer is (c).
In the case of Sharada Devi Vs. Chandwala, the Supreme Court held that surrender by a tenant is not a transfer of tenancy rights. The Court held that surrender is a unilateral act of the tenant and does not require the consent of the landlord. The Court also held that surrender does not extinguish the tenant’s rights under the tenancy agreement, but merely terminates the tenancy.
The other options are incorrect. In the case of Bachchu Vs. Harbansh, the High Court of Allahabad held that surrender by a tenant is a transfer of tenancy rights. The Court held that surrender is a bilateral act of the tenant and the landlord, and that the landlord’s consent is necessary for surrender to be valid. In the case of Makhanlal Saha Vs. N.N. Adhikari, the High Court of Calcutta held that surrender by a tenant is a transfer of tenancy rights. The Court held that surrender is a bilateral act of the tenant and the landlord, and that the landlord’s consent is necessary for surrender to be valid.
In conclusion, the correct answer is (c). In the case of Sharada Devi Vs. Chandwala, the Supreme Court held that surrender by a tenant is not a transfer of tenancy rights.