Arbitrary rent ceiling classification under lease control law violated equality guarantees and was struck down.

Section 30(ii) of the Tamil Nadu Buildings (Lease and Rent Control) Act, 1960 was found to create an arbitrary classification by denying statutory protection only to residential premises let above the prescribed rent ceiling while continuing protection for non-residential premises regardless of rent. The Court held that no rational basis was shown for this differential treatment, and the justification based on protection of weaker sections did not explain the exclusion of higher-rent residential tenants. As the rent ceiling had become unreal with rising rents, the classification lacked a reasonable nexus with the object of the Act and was struck down as violative of Article 14.

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Issues: Whether section 30(ii) of the Tamil Nadu Buildings (Lease and Rent Control) Act, 1960, which excludes residential buildings or parts thereof let for monthly rent exceeding Rs. 400, is violative of Article 14 of the Constitution of India.

Analysis: The statutory scheme was intended to regulate letting, control rents and prevent unreasonable eviction in respect of residential and non-residential buildings alike. The exclusion created by section 30(ii) singled out tenants of residential premises above the prescribed rent ceiling while continuing to protect tenants of non-residential premises irrespective of the rent paid. No rational basis was shown for this differential treatment, and the attempted justification based on protection of weaker sections did not explain why tenants of higher-rent residential premises alone were denied statutory protection. The ceiling had also become unreal with the passage of time and the rise in rents, making the classification arbitrary and lacking a reasonable nexus with the object of the Act.

Conclusion: Section 30(ii) was held unconstitutional as violative of Article 14 and was struck down.

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