Regular payment of rent as an independent eviction ground remains unaffected by separate arrears proceedings.

The statutory scheme treated regular payment of rent as an independent ground for eviction, distinct from the landlord's separate remedy for arrears. In assessing whether the tenant failed to pay rent regularly without sufficient cause, conduct both before and after the commencement of the relevant protective provision could be considered where it formed part of the statutory test. Repeated non-payment over several years, together with the absence of a bona fide attempt to use the statutory protection for arrears proceedings, supported liability to eviction. Payment made in the arrears proceedings did not remove the separate eviction ground based on irregular payment without sufficient cause.

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Issues: Whether the tenant was liable to eviction under the statutory ground of failure to pay rent regularly without sufficient cause, and whether the landlord's separate remedy for recovery of arrears of rent affected that liability.

Analysis: The statutory scheme distinguished between an application for eviction on the grounds enumerated in Section 9 and an application for recovery of arrears under Section 14-A(ii). The ground under Section 9(1)(ii) turned on the tenant's conduct in regularly paying rent and the existence of sufficient cause for default. In assessing that ground, conduct preceding the commencement of Section 14-A could be taken into account because the provision used past and continuing conduct as a constituent of the statutory test. The tenant's repeated non-payment over several years, coupled with the absence of a bona fide attempt to invoke the protective mechanism in Section 14-A(iii), supported the finding that rent had not been paid regularly without sufficient cause. Payment made pursuant to the arrears proceedings did not neutralize the independent ground for eviction under Section 14-A(1).

Conclusion: The tenant was rightly held liable to eviction on the ground that he had failed to pay rent regularly without sufficient cause, and the order of eviction was sustainable.

Ratio Decidendi: Where a statute treats regular payment of rent as an independent ground of eviction, the tenant's pre-commencement and post-commencement conduct may both be considered if the conduct is part of the statutory condition, and compliance in separate arrears proceedings does not defeat a distinct eviction ground.

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