MAC Inmex, Inc. v. Dinesh Jasani

Court of Appeals of Virginia·Decided July 14, 2026·No. 1138254·Unpublished

Opinion

COURT OF APPEALS OF VIRGINIA Record No. 1138-25-4

MAC INMEX, INC.

v.

DINESH JASANI, ET AL.

Present: Judges AtLee, Friedman and Senior Judge Annunziata Argued at Alexandria, Virginia Opinion Issued July 14, 2026*

FROM THE CIRCUIT COURT OF STAFFORD COUNTY Michael E. Levy, Judge

Cullen D. Seltzer (Andrew Biondi; Sands Anderson PC, on briefs), for appellant.

(Stephen E. Heretick; Stephen E. Heretick, P.C., on brief), for appellees. Appellees submitting on brief.

MEMORANDUM OPINION BY

JUDGE ROSEMARIE ANNUNZIATA

MAC Inmex, Inc., appeals the circuit court’s judgment awarding possession of a commercial premises to Dinesh Jasani and Vinay Kakadia (collectively, the landlord). MAC Inmex is the successor company of a 2023 merger between two corporations to which the landlord had leased the property in 2016. The circuit court found that MAC Inmex’s assumption of the tenancy after the merger violated the lease’s prohibition on assignments or transfers without the landlord’s written permission. The court rejected MAC Inmex’s argument that a 2019 amendment to Code § 13.1-721, which explicitly provides that a merger is not a “transfer,” applied to the case. For the following reasons, we affirm the court’s judgment.

*

This opinion is not designated for publication. See Code § 17.1-413(A).

BACKGROUND

In August 2016, Marvi, Inc. and Ziya, Inc. signed a lease renting commercial property from the landlord for a 10-year term. The lease required the tenants to obtain the landlord’s written consent to “transfer or assign” their tenancy. In 2023, Marvi and Ziya merged to become MAC Inmex. After the merger, MAC Inmex claimed to be the tenant under the lease and satisfied all contractual obligations.

Marvi and Ziya did not obtain the landlord’s written consent to transfer or assign the lease to MAC Inmex. In January 2024, the landlord sent Marvi, Ziya, and the lease guarantors a notice of intent to cure, asserting that the merger violated the lease’s prohibition on transfers or assignments. Marvi and Ziya responded that they had not violated the lease because, upon merger, all rights vested in MAC Inmex as the successor company.

The landlord filed an unlawful detainer asserting that the merger violated the non-transfer clause. Before trial, MAC Inmex filed a brief arguing that under Code § 13.1-721, a merger was not a “transfer, reversion or impairment,” and that “every contract right” Marvi and Ziya possessed automatically vested in MAC Inmex. Thus, MAC Inmex maintained that the lease agreement did not require the landlord’s written consent “for a merger.” MAC Inmex acknowledged that Code § 13.1-721 was amended in 2019 and asserted that the amendment “evidence[d] a clear legislative intent that a merger” is not “a transfer or assignment.” Indeed, MAC Inmex’s brief posited that the 2019 amendments effected a change in the law by acknowledging that if the merger had occurred before the 2019 amendments, “the amendment could not be applied retroactively to implement the expanded rights of the statute to a merger that predated the enactment.” (Emphasis added). Still, MAC Inmex argued that it could rely on the 2019 amendment’s “expanded rights” because the merger did not occur until 2023.

At the bench trial, MAC Inmex reiterated that under Code § 13.1-721, a merger was “a complete transfer of all rights, contractual and otherwise.” MAC Inmex asserted, “that change in the law occurred in 2019,” and the merger did not occur until 2023. (Emphasis added). MAC Inmex again acknowledged that if the merger had predated the 2019 amendments, the change in the statute “would not have retroactively cured that merger.” Consequently, MAC Inmex argued that under the 2019 amendments, the merger was “not an assignment or a transfer.” The landlord countered that the version of Code § 13.1-721 in effect when the lease was signed in 2016 controlled interpretation of the lease. The landlord asserted that under the 2016 version, the merger caused a “transfer,” which violated the lease’s non-transfer clause. See Code § 13.1-721(A)(3) (2016); 2005 Va. Acts ch. 765.

Following argument, the circuit court held that the lease should be interpreted under the law that existed when it was signed in 2016, not the 2019 amendment. The court found that the 2019 amendment does not apply retroactively to control the lease’s interpretation and that the parties’ contractual rights established in 2016 could not be effected by the amendment. Thus, the court held that MAC Inmex’s assumption of the tenancy after the merger without the landlord’s written consent violated the lease’s non-transfer clause. Accordingly, it awarded landlord possession of the premises.

On appeal, MAC Inmex argues that the circuit court erred by awarding the landlord possession of the premises because the 2019 amendment to Code § 13.1-721 was procedural only and did not effect a substantive change to the law. Rather, the amendment merely “clarified ambiguities” in the statute regarding the effect of mergers. MAC Inmex insists that a merger is not and never has been a “species” of assignment as a matter of law, so it must prevail irrespective of which version of the statute applied. Alternatively, MAC Inmex asserts that the court erred by finding that the 2019 amendments did not have “retrospective application.”

ANALYSIS

I. MAC Inmex has approbated and reprobated by assuming contradictory positions at trial and on appeal, and many of its arguments are not preserved.

“No ruling of the trial court . . . will be considered as a basis for reversal unless an objection was stated with reasonable certainty at the time of the ruling, except for good cause shown or to enable this Court to attain the ends of justice.” Rule 5A:18. “Specificity and timeliness undergird the contemporaneous-objection rule, animate its highly practical purpose, and allow the rule to resonate with simplicity.” Hogle v. Commonwealth, 75 Va. App. 743, 755 (2022) (quoting Bethea v. Commonwealth, 297 Va. 730, 743 (2019)). Indeed, the “precise nature” of the argument “must be clear because ‘[m]aking one specific argument on an issue does not preserve a separate legal point on the same issue’” for review. Mollenhauer v. Commonwealth, 73 Va. App. 318, 329 (2021) (alteration in original) (quoting Johnson v. Commonwealth, 58 Va. App. 625, 637 (2011)). Even where a position remains the same, a party may not raise a new rationale for that position on appeal and expect this Court to consider it as an initial proposition. See Commonwealth v. Holland, 304 Va. 34, 38 (2025) (“Appellate courts are a court of review, not first view.”). “[N]either an appellant nor an appellate court should ‘put a different twist on a question that is at odds with the question presented to the [circuit] court.” Bethea, 297 Va. at 744 (quoting Commonwealth v. Shifflett, 257 Va. 34, 44 (1999)).

Further, a “litigant cannot ‘approbate and reprobate by taking successive positions in the course of litigation that are either inconsistent with each other or mutually contradictory,’ or else such arguments are waived.” Amazon Logistics, Inc. v. Va. Emp. Comm’n, 304 Va. 107, 114 (2025) (quoting Rowe v. Commonwealth, 277 Va. 495, 502 (2009)). The doctrine “applies both to assertions of fact and law.” Nelson v. Commonwealth, 71 Va. App. 397, 403 (2020) (quoting Babcock & Wilcox v. Areva, 292 Va. 165, 204-05 (2016)). And it protects “basic notions of fair play in our adversarial system.” Amazon Logistics, Inc., 304 Va. at 107. Litigants “must ‘elect a

particular position’ and are thereafter confined ‘to the position that [they] first adopted.’” Id. at 115 (alteration in original) (quoting Matthews v. Matthews, 277 Va. 522, 528 (2009)).

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