On the issue of forfeiture, the Eleventh Edition of the Black’s Law Dictionary, defines the phenomenon as: “The loss of a right, privilege, or property because of a crime, breach of obligation, or neglect of duty. The title is instantaneously transferred to another, such as the government, a corporation, or a private person”. Section 17 of the Rents Act, 1963 (Act 220), which is instructive on the topic of forfeiture, provides that: (1) Subject to subsection (2) of section 25 and to section 28, an order against a tenant for the recovery of the possession of, or for the ejectment from, any premises shall not be made or given by the Rent Magistrate or any other judge of a court of competent jurisdiction in accordance with any other enactment except (b) where an obligation of the tenancy, other than that specified in paragraph (a) (rent), so far as that obligation is consistent with this Act, has been broken or not performed; Similarly, section 29 of the Conveyancing Decree sheds useful light on the topic: (1) A right of re-entry or forfeiture under any provision in a lease for a breach of any covenant, condition or agreement in the lease shall not be enforceable, by action or otherwise, until— (a) the lessor serves on the lessee a notice: (i) specifying the particular breach complained of; (ii) if the breach is capable of remedy, requiring the lessee to remedy the breach; and (iii) (except where the breach consists of a non-payment of rent) requiring the lessee to make reasonable compensation in money for the breach; and (b) the lessee has knowledge of the fact that such notice has been served; and the lessee fails, within a reasonable time thereafter, to remedy the breach, if it is capable of remedy and (except where the breach consists of a non-payment of rent) to make reasonable compensation in money, to the satisfaction of the lessor, for the breach. In the recent decision of this Court in the case of Royal Investment Company Vrs Quarcoopome and Another (66 of 2021) [2021] GHASC 104 (1st December 2021), the erudite Amegatcher JSC. opined as follows: “On the other hand, where there was a breach of a covenant there could not be forfeiture unless there was an express provision for re-entry in the lease based on the breach of the said covenant. This position was advanced by Ollennu J (as he then was) in the case of BASSIL v SAID RAAD & SONS (1958) 3 WALR 231 as follows: “Now at common law, there can be no forfeiture for breach of covenant under a lease unless there is an express provision in the lease for re-entry”.