The COVID-19 pandemic “has had the effect of frustrated the lease” as the complainant tenant “is unable to use demised`s Premise or generate revenue for obvious health and safety issues.” In addition to claims of impossibility and inefficiency, the tenant endeavors to rework the lease to include an “implied force majeure clause” and resignation based on this implied clause.) (25.08.2020 Appeals) (09.10.2020 Reply by counter-claims) Rental agreements often involve an obligation of silent enjoyment, with the lessor obliging that the use of the premises is not disturbed by the lessee, provided that the lessee has fulfilled his obligations under the lease agreement. . . .