Lessor's Right to Terminate Lease Without Formal Notice for Rent Arrears

A commercial lease agreement stipulated that rent was payable in advance on the first day of each quarter, and contained a clause allowing the lessor to terminate the lease without formal notice if rent was unpaid on the due date. When the lessee failed to pay the rent due on October 1st, the lessor initiated eviction proceedings, arguing that the explicit termination clause did not require a formal notice to pay before exercising the right to terminate. The court upheld the lower court's decision to reject the eviction claim, reasoning that even when a lease explicitly waives the need for formal notice (mise en demeure) for termination due to non-payment, such a clause does not supersede the general legal requirement that a debtor must be formally put on notice before a debt can be considered definitively overdue and trigger contractual remedies like termination, unless the contract explicitly provided for immediate termination upon mere non-payment without any prerequisite formality.