The tenant’s breaches of its obligations, where they continue “repeatedly, recently and after the renewal of the lease” and are “taken as a whole”, may be “sufficiently serious to warrant termination of the lease between the parties” under Article 1184 of the Civil Code.

Furthermore, the fact that the landlord is deemed to have accepted the principle of renewal by failing to respond within three months to the tenant’s request for renewal (Article L. 145-10 of the Commercial Code) does not amount to a waiver of its right to rely on the grounds for termination invoked in pre-existing proceedings.