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Issues:
- Interpretation of Section 11(1)(a) of the Bihar Buildings (Lease, Rent and Eviction) Control Act, 1947. - Jurisdiction of the House Controller in ordering eviction based on non-payment of rent. - Applicability of the decision of the Controller and its challenge in a civil court. Analysis: 1. The case involved an appeal from a judgment of the High Court of Judicature at Patna regarding the eviction of tenants by the appellants. The respondents, monthly tenants, had remitted rent that was in arrears, but the appellants claimed non-payment of rent, leading to eviction proceedings under Section 11(1)(a) of the Bihar Buildings Control Act, 1947. 2. The respondents deposited rent up to June after the appellants returned their initial payment. Despite this, the House Controller ordered eviction, upheld by the Commissioner. The respondents then filed a suit challenging the eviction order, which was initially dismissed but later decreed by the High Court, leading to the current appeal. 3. The main contention was whether there was actual non-payment of rent as required by the Act. The appellants argued that the rent was not paid when due, justifying eviction. The lower courts upheld the Controller's decision, stating that his jurisdiction was final and not subject to civil court review. 4. The High Court disagreed, emphasizing the Act's aim to prevent unjust evictions. It questioned the interpretation of non-payment of rent and the Controller's authority. It concluded that the Controller's decision could be challenged in a civil court, contrary to the lower courts' view. 5. The Supreme Court held that Section 11 was self-contained, empowering the Controller to decide on eviction conditions. Citing legal principles, it stated that if the Controller had jurisdiction to determine non-payment of rent, his decision could not be questioned in a civil court. The Court rejected the High Court's interpretation and reinstated the lower courts' decree in favor of the appellants.
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