Parliament's cantonment-area housing power includes rent control and eviction, so state tenancy law could validly extend there.

Parliament's exclusive power over the regulation of house accommodation in cantonment areas was construed broadly to include letting, control of rents, termination of tenancies and eviction. The Court held that civilian occupation in a cantonment area did not narrow that constitutional entry, and the reference to control of rents confirmed its width. Because the subject fell within List I, the State's general legislative power over landlord-tenant relations yielded to Parliament's competence under Article 246. The extension of the West Bengal Premises Tenancy Act to the cantonment area was therefore upheld, and the competence challenge failed.

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Issues: Whether the State rent control law, as extended to a cantonment area, was ultra vires because the regulation of house accommodation in cantonment areas, including control of rents and eviction of tenants, fell within the exclusive legislative competence of Parliament.

Analysis: The constitutional entry conferring power on Parliament over the regulation of house accommodation in cantonment areas was construed broadly. The expression was held to include all aspects of control over occupation of houses in such areas, including letting, termination of tenancies, eviction, and fixation of rents. The existence of civilian occupation in cantonment areas did not narrow the entry, and the presence of the words "including control of rents" confirmed the width of the power. Because the subject fell within List I, the State Legislature's general power over landlord-tenant relations in the other Lists yielded to Parliament's exclusive competence under Article 246.

Conclusion: The extension of the West Bengal Premises Tenancy Act to the cantonment area was valid, and the challenge to its competence failed.

Ratio Decidendi: Where a constitutional entry in List I expressly covers regulation of house accommodation in cantonment areas, that power extends to rent control and eviction, and State legislation on landlord-tenant relations is excluded to the extent of that field.

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