Our state’s highest court has made clear that the RRA demands a “‘landlord's punctilious
compliance with all statutory eviction procedures, including notice provisions.’” In re Soon
Kwon, 2011 VT 26, ¶ 14, 189 Vt. 598 (citation omitted). As far as this court can tell, our state
supreme court has not defined “punctilious” in the eviction context. It has used the term in three
landlord-tenant cases, ruling twice for the tenant. See Vermont Small Bus. Dev. Corp. v. Fifth
Son Corp., 2013 VT 7, ¶ 15, 193 Vt. 185 (“There is no reason to require less ‘punctilious
compliance’ with terms of a lease providing for notice in the nonresidential context.”); In re Soon
Kwon, 2011 VT 26, ¶ 14. In its single ruling for the landlord, the Court limited and clarified its
holding to circumstances not applicable to this case. Panagiotidis v. Galanis, 2015 VT 134, ¶ 9,
201 Vt. 57 (“We did not intend to suggest that, in a nonresidential context, we would refuse to
accept a form of notice that is at least as effective, and actually more certain, than that provided
in the lease.”) The court concludes that the Vermont Supreme Court used the word “punctilious”
in this context with all the word’s unambiguously demanding denotation and connotation.