Purposive interpretation of rent-control proviso extends first-date tender benefit to a claimed tenant, not just an admitted tenant.

A beneficial rent-control proviso must be construed purposively to prevent eviction for default while ensuring prompt payment of arrears, interest, and costs. The Court held that the definition of tenant in the Act does not rigidly confine the proviso where such a reading would defeat the legislative object or cause premature eviction before the tenancy dispute is resolved. Accordingly, the right to tender arrears on the first date of hearing is available not only to an admitted tenant but also to a person who claims to be a tenant, and the contrary view was rejected.

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Issues: Whether the benefit of the proviso to Section 13(2)(i) of the East Punjab Urban Rent Restriction Act, 1949, is confined only to an admitted tenant, or can also be availed of by a person claiming to be a tenant while tendering arrears of rent on the first date of hearing.

Analysis: The proviso was construed in the light of the object of rent-control legislation, namely, to protect tenants from eviction for default while securing prompt payment of arrears, interest, and costs to the landlord. The definition of tenant in the Act was held not to control the proviso rigidly where such a construction would produce injustice or defeat the legislative purpose. The Court emphasized that statutory interpretation must look to the context, the scheme of the Act, and the beneficial object of the provision. A restrictive view that only an admitted tenant could tender the amount was found capable of causing arbitrary eviction before the real controversy regarding tenancy or sub-tenancy was adjudicated.

Conclusion: The benefit of the proviso is available not only to the admitted tenant but also to a person claiming to be a tenant. The contrary view of the High Court was overruled, and the appeal was allowed with remand.

Ratio Decidendi: A beneficial rent-control proviso enacted to prevent eviction for default must be construed purposively, and the right to tender arrears on the first date of hearing is not confined to an admitted tenant where the applicant asserts tenancy and the issue remains unresolved.

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