Finality under rent control law bars second revision to High Court after statutory revisional remedy is exercised.

Under the Kerala Building (Lease & Rent) Control Act, a further revision under Section 115 CPC was held to be barred after the District Court exercised revisional jurisdiction under Section 20. The Act was read as a self-contained statutory scheme with appeal and revision remedies, and Section 18(5) was treated as a finality clause that confines challenge to the modes expressly provided by the Act. Because Section 20 itself supplied the complete revisional remedy and permitted remand, the High Court's supervisory revisional jurisdiction was excluded at the second stage. A dissent maintained that Section 115 CPC remained available.

---

---

Issues: Whether, under the Kerala Building (Lease & Rent) Control Act 2 of 1965, a further revision lay to the High Court under Section 115 of the Code of Civil Procedure against an order passed by the District Court in revision under Section 20, notwithstanding the finality language in Section 18(5).

Analysis: The relevant scheme of the Kerala Act provides a first-tier decision by the Rent Control Court, an appeal under Section 18, and a revision under Section 20. Section 18(5) declares that the decision of the appellate authority, and subject to it the order of the Rent Control Court, shall be final and shall not be called in question in any court of law except as provided in Section 20. The revisional power under Section 20 is itself a complete statutory remedy, and Section 20A expressly authorises remand. Reading Sections 18(5) and 20 together, the finality clause was held to exclude a second revision under Section 115 CPC to the High Court after the District Court has exercised revisional jurisdiction. The Act was treated as a self-contained scheme intended to limit litigation and secure finality within the statutory hierarchy.

Conclusion: A further revision to the High Court under Section 115 CPC was held not to lie against a revisional order of the District Court under Section 20 of the Kerala Act.

Concurring Opinion: Natarajan, J. delivered the majority view. Ranganathan, J. dissented and held that the High Court's revisional jurisdiction under Section 115 CPC was not excluded by the Kerala Act.

Ratio Decidendi: Where a special rent control statute creates a complete hierarchy of remedies and a finality clause that confines challenge to the modes expressly provided by the Act, a second revision under Section 115 CPC is impliedly barred.

---