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Issues Involved:
1. Applicability of Section 8 of the Delhi and Ajmer Rent Control Act, 1952 2. Relationship of landlord and tenant 3. Compliance with Section 47 of the Punjab Municipal Act, 1911 4. Estoppel against the Committee Detailed Analysis: 1. Applicability of Section 8 of the Delhi and Ajmer Rent Control Act, 1952 The primary issue was whether Section 8 of the Delhi and Ajmer Rent Control Act, 1952 (the Act) applied to the transactions between the appellants and the New Delhi Municipal Committee (the Committee). The appellants argued that the Act's provisions should apply, asserting that the Transfer of Property Act did not govern these transactions, and thus, a registered lease was unnecessary. They contended that the terms of tenancies could be ascertained from written Kabuliyats. The Committee, however, argued that the essential element of "letting" required a valid contract creating an interest in immovable property, which was absent due to non-compliance with Section 47 of the Punjab Municipal Act. 2. Relationship of Landlord and Tenant The core question was whether there was a landlord-tenant relationship between the parties. The Trial Court initially found that such a relationship existed, making the applications for standard rent fixation competent. However, the High Court reversed this finding, concluding that no valid lease existed due to the lack of a properly executed lease and the inapplicability of the doctrine of part performance. The Supreme Court upheld this view, emphasizing that the Act applied only to "letting" that created an interest in immovable property, which was not the case here due to the absence of a valid contract. 3. Compliance with Section 47 of the Punjab Municipal Act, 1911 Section 47 mandates that every transfer of immovable property by the Committee must be executed in writing, signed by the President or Vice-President and at least two other members, and attested by the Secretary. The appellants argued that non-compliance with these formalities rendered the contract voidable, not void. However, the Court held that the provisions of Section 47 were mandatory, not merely directory. The absence of compliance with these statutory requirements meant that no valid transfer of property occurred, and thus no landlord-tenant relationship was created. 4. Estoppel Against the Committee The appellants contended that the Committee was estopped from denying the landlord-tenant relationship, having accepted rent. However, the Court ruled that there could be no estoppel against a statute. The statutory requirements under Section 47 had to be strictly followed, and non-compliance rendered the transactions legally ineffective. The Court cited Halsbury's Laws of England to support the principle that a statutory body cannot be estopped from denying a contract it was ultra vires to make. Conclusion: The Supreme Court dismissed the appeals, affirming that there was no landlord-tenant relationship between the parties due to the non-compliance with Section 47 of the Punjab Municipal Act. Therefore, the applications under Section 8 of the Delhi and Ajmer Rent Control Act were rightly dismissed by the High Court as incompetent. The appeals were dismissed with costs, and one set of hearing fees was imposed.
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