Kündigung eines Mieters wegen fehlender angemessener wirtschaftlicher Verwertung

Allgemein bekannt ist, dass einem Mieter durch den Vermieter gekündigt werden kann, wenn dieser die vermietete Wohnung für den Eigenbedarf benötigt. Weniger bekannt ist, dass der dafür anzuwendender Paragraf 573 des Bürgerlichen Gesetzbuches auch eine Kündigung des Mietverhältnisses erlaubt, wenn sonst keine „angemessene(n) wirtschaftlichen Verwertung des Grundstücks“ möglich ist. Nun hat der Bundesgerichthof in einem Einzelfall interessante Aussagen zur angemessenen wirtschaftlichen Verwertung als Begründung einer Kündigung gemacht.

In dem behandelten Einzelfall wollte eine Erbengemeinschaft ein Einfamilienhaus der ehemaligen DDR verkaufen und hierzu die darin lebende Mieterin kündigen. Diese hatte nach einer langen Mietdauer einen für einen potentiellen Käufer wenig attraktiven Mietvertrag.

Generell ist es so, dass eine Immobilie besser verkaufbar ist, wenn sie unvermietet oder mit einem marktüblichen Mietzins ausgestattet ist. Allerdings sagt der oben verlinkte Paragraf des Bürgerlichen Gesetzbuches, dass die Mietsituation für den Vermieter mit „erheblichen Nachteilen“ verbunden sein muss, damit er eine rechtswirksame Kündigung wegen fehlender wirtschaftlicher Verwertung aussprechen kann.

Der Bundesgerichtshof hat in seiner Entscheidung bekräftigt, dass es hierfür einer Einzelabwägung in jeden Fall einer Kündigung wegen fehlender wirtschaftlicher Verwertung bedürfe und deshalb den konkreten Fall an das Berufsgericht zurückverwiesen. Dieses habe es sich in seiner Entscheidung zu einfach gemacht: „Anders als das Berufungsgericht gemeint hat, kann ein erheblicher Nachteil nicht schon deshalb verneint werden, weil die Kläger das Grundstück als Erben bereits im vermieteten und unrentablen Zustand erworben haben und seit dem tatsächlichen Eintritt der Kläger in das Mietverhältnis bei Beendigung der staatlichen Verwaltung keine wesentliche Verschlechterung eingetreten ist.“ (Zitat aus der oben verlinkten Pressemitteilung des Bundesgerichtshofs)

Man kann aus dieser Entscheidung also folgern, dass sich grundsätzlich nichts an der Rechtslage zur Kündigungsmöglichkeit wg. fehlender wirtschaftlichen Verwertung der Immobilie geändert hat. In jeden Einzelfall sind die konkreten Gründe zu ermitteln und die Interessenlage der beteiligten Vertragsparteien des Mietverhältnisses zu berücksichtigen.

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  337. After I initially left a comment I seem to have clicked on the -Notify me when new comments are added- checkbox and now each time a comment is added I recieve four emails with the same comment. There has to be a means you are able to remove me from that service? Many thanks!

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