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Résilier un bail commercial sans jugement? oui c’est possible!

Les motifs de résiliation d’un bail commercial sont nombreux et ils peuvent émaner tant du locateur que du locataire. Pensons simplement au locataire qui néglige le paiement du loyer ou au locateur qui n’effectue pas les travaux mentionnés au bail.

La résiliation judiciaire d’un bail commercial peut s’avérer une aventure longue et coûteuse et c’est pourquoi les rédacteurs de baux incluent depuis longtemps des clauses de résiliation automatique du bail en cas de défaut. Malgré ces clauses, les tribunaux étaient encore réticents à reconnaître une résiliation sans poursuite judiciaire.

Pourtant l’article 1605 du Code civil du Québec, introduit en 1994, laissait planer l’impression que la résiliation automatique était désormais possible :

 » La résolution ou la résiliation du contrat peut avoir lieu sans poursuite judiciaire lorsque le débiteur est en demeure de plein droit d’exécuter son obligation ou qu’il ne l’a pas exécutée dans le délai fixé par la mise en demeure.  »

Malgré cette disposition, les tribunaux étaient réticents à accorder la résiliation automatique des baux commerciaux. Une décision était même venue dire que  » dans le cas des baux, le législateur avait choisi de maintenir comme règle générale la nécessité d’ester en justice afin d’obtenir la résiliation du contrat « .

Nouveau développement jurisprudentiel :

Le 1 avril 2003, la Cour d’appel du Québec a rendu une décision majeure dans le dossier : 9051-5909 Québec Inc. c. 9067-8665 Québec Inc. En effet cet arrêt vient nous éclairer sur les conditions nécessaires à la résiliation sans poursuite d’un bail commercial.

Les faits en cause étaient très simples. Un restaurateur avait fait défaut de payer son loyer commercial à plusieurs reprises. Suite à une mise en demeure, la locatrice intente, en mai 1999, une requête dans laquelle elle demande la résiliation du bail, l’expulsion ainsi que des dommages et intérêts. Trois jours plus tard, la locatrice change d’idée et décide de se prévaloir de la clause du bail lui permettant d’exiger la résiliation de plein droit du contrat. La locatrice avise les locataires de sa nouvelle décision en envoyant un avis d’expulsion et elle fait fermer le restaurant dès le lendemain.

Le bail contenait la clause suivante :  » À défaut par le locataire de payer le loyer à échoir en vertu du présent bail à chacune des échéances ci-dessus fixées, ou de remplir les conditions du présent bail et de tout renouvellement, ce dernier sera résolu de plein droit, à l’option du bailleur, sans préjudice au droit de ce dernier de recouvrer le loyer échu et à échoir en vertu du présent bail.  »

La Cour d’appel mentionne dans son jugement :  » rien ne permet de conclure à l’invalidité de cette clause. En outre, ce genre de clause semble aller dans le sens que le législateur a voulu favoriser en adoptant la règle prévue à l’article 1605 C.c.Q. Comme il a été prouvé que les locataires ont fait défaut de respecter leur obligation de payer le loyer convenu, le juge aurait donc dû conclure que la locatrice pouvait effectivement résilier le bail de plein droit.  »

On peut donc en conclure que la résiliation sans poursuite judiciaire d’un bail commercial est désormais possible. Cependant certaines conditions sont nécessaires :

  1. Présence d’une clause non équivoque prévoyant la résiliation de plein droit du bail en cas de défaut du locataire.
  2. Ne pas avoir commencer une poursuite en résiliation devant les tribunaux. En effet, l’article 1883 C.c.Q. confère au locataire poursuivi en résiliation de bail, pour défaut de paiement de loyer, le droit d’éviter la résiliation en payant, avant que jugement ne soit rendu, le loyer dû au locateur ainsi que les frais et les intérêts. Ainsi dans l’arrêt : 9051-5909 Québec Inc. c. 9067-8665 Québec Inc, la locatrice fût privée de la résiliation automatique puisqu’elle avait déposé une requête en résiliation trois jours auparavant.
  3. La conduite du locateur ne doit pas être abusive. Le délai entre le moment de l’avis de la résiliation imminente et le moment de reprise de possession des locaux ne doit pas être trop court.

Conclusion

Il semble que l’incertitude qui planait sur la possibilité de résilier un bail commercial sans poursuite judiciaire soit donc grandement dissipée depuis avril 2003. Il ne faut cependant pas conclure qu’il s’agit d’une solution miracle puisque le locataire qui reçoit un avis de résiliation peut prendre les devants et introduire une instance en opposition à la résiliation et reporter l’éviction effective jusqu’à ce que les tribunaux aient tranchés la question.

Afin de vous assurer que les dispositions de votre bail sont conformes à vos attentes, nous vous recommandons de les faire vérifier par un spécialiste.

À propos de l’auteur

Me Luc Audet est avocat et membre du Barreau du Québec depuis 1981. Sa pratique est essentiellement consacrée au droit des affaires. Il est également investisseur immobilier, ce qui lui permet de bien comprendre le «langage immobilier» et de conseiller sa clientèle non seulement en droit immobilier, mais aussi comme investisseur.Le site web principal du cabinet Audet & Associés Avocats, Inc. est www.DroitDesPME.com

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