Public authority eviction and reallotment must be reasonable, public-interest driven, and not arbitrary under Article 14.

A Port Trust, though exempt from rent control, remained subject to Article 14 and was required to act reasonably, in public interest, and for proper statutory purposes when evicting a tenant and reallotting a reconstituted plot. Its conduct could be judicially reviewed for arbitrariness, but the court would not substitute its own view for a possible policy choice made on relevant considerations. On the facts, allotting the reconstituted plot to the holder of the major portion for development under the town planning scheme was treated as a legitimate policy decision linked to public purpose. The challenge to the eviction and allotment therefore failed.

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Issues: Whether the Port Trust, as a public authority exempt from rent control, was bound to act reasonably and in public interest while evicting the tenant and allotting the reconstituted plot to another occupant, and whether its decision was open to judicial review as arbitrary or improper.

Analysis: The exemption from rent control rested on the assumption that the Port Trust would not act like an ordinary private landlord and would exercise its statutory powers for public purposes. As a public authority and an instrumentality of the State, its conduct in dealing with tenants was subject to Article 14 and could be examined to see whether it was informed by reason and public interest. At the same time, judicial review could not be expanded into substitution of the Court's own view for a policy choice made by the authority if the choice was a possible one taken on relevant considerations. On the facts, the decision to allot the reconstituted plot to the holder of the major portion for development was treated as a policy decision linked to the public purpose of development under the town planning scheme, and not as an improper or arbitrary exercise of power.

Conclusion: The Port Trust's action was held to be lawful, reasonable, and not arbitrary, and the challenge to the eviction and allotment failed.

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