Mandatory statutory rent cannot be overridden by mistake, and a patent error may be corrected despite no review power.

A public authority may correct a patent mistake in annual rent fixation where the original rate conflicted with mandatory statutory rules governing allotment, and the corrected demand remains valid. The absence of an express review power does not bar correction of an order that was never a lawful relaxation under the enabling framework, and equitable estoppel cannot be invoked to sustain a position contrary to statute. Applying the statutory rent formula under the relevant allotment rules, the Supreme Court held the corrected rent demand valid, set aside the High Court's order, and dismissed the writ petition.

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Issues: Whether the administration could correct a patent mistake in the fixation of annual rent under the statutory rules after a long lapse of time, and whether the demand raised pursuant to such correction was invalid for want of review power or on the ground of estoppel.

Analysis: The allotment was governed by the Capital of Punjab (Development and Regulation) Act, 1952 and the Chandigarh Lease-hold of Sites and Buildings Rules, 1973. Rule 13 prescribed mandatory annual rent at a fixed percentage of the premium, leaving no discretion to charge a lower rent. The original allotment rate was contrary to the rule, and the administration merely corrected that patent illegality without cancelling the allotment. Since the earlier fixation was not a conscious relaxation under any enabling power, the absence of a review provision did not prevent correction of the mistake. The plea of equitable estoppel could not succeed against a statutory mandate.

Conclusion: The demand notice was valid and the challenge to the corrected rent fixation failed.

Final Conclusion: The appeal succeeded, the High Court's order was set aside, and the writ petition stood dismissed.

Ratio Decidendi: A public authority may correct a patent mistake that conflicts with mandatory statutory rules, and neither absence of review power nor equitable estoppel can sustain an order contrary to statute.

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