Landlord-Tenant—Holdover Proceeding May Proceed—Tenant Had Waived His Right To Return to Religious (Bet Din) Arbitration

A landlord commenced a holdover proceeding on the grounds that the subject lease had expired. Prior to the commencement of the subject proceeding, in March 2022, the parties had submitted their dispute to arbitration before a rabbinical court (Bet Din).

The rabbinical court held that the tenant must vacate the apartment by Feb. 28, 2023. However, the tenant had failed to timely vacate the apartment and in late March 2023, the landlord served a 90-day notice of termination pursuant to Real Property Law §§232-a and 226-c.