Overriding special remedy under rent control law prevails over slum clearance permission requirements for landlord eviction proceedings.

Section 14A and Chapter IIIA of the Delhi Rent Control Act create an immediate, special remedy for specified landlords and contain an overriding procedural scheme that prevails over inconsistent law. The protective requirement of prior permission under section 19 of the Slum Areas (Improvement and Clearance) Act cannot defeat that later and special remedy, because the 1975 amendments were intended to operate effectively despite earlier non obstante clauses. Accordingly, eviction proceedings under section 14A may be instituted in a slum area without obtaining prior permission from the competent authority.

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Issues: Whether the provisions of the Delhi Rent Control Act, 1958, particularly section 14A and Chapter IIIA, override the protective and procedural requirements of section 19 and section 39 of the Slum Areas (Improvement and Clearance) Act, 1956, so that a landlord covered by section 14A can institute eviction proceedings in a slum area without prior permission of the competent authority.

Analysis: Section 14A was introduced to confer an immediate right on a specified class of landlords to recover possession of premises let out by them. Chapter IIIA, especially sections 25A and 25B, gives that right an overriding procedural framework and expressly provides that its provisions prevail over anything inconsistent contained in the Delhi Rent Control Act or in any other law. Section 14A itself is cast in wider overriding language and is not confined by the consistency qualifier used elsewhere. The protective scheme of the Slum Areas (Improvement and Clearance) Act, 1956, including the requirement of prior permission under section 19 and the general overriding clause in section 39, would defeat the object of the later and special remedy created by the 1975 amendments if allowed to operate against proceedings under section 14A. The later enactment, made with knowledge of the earlier non obstante provisions, was intended to provide an effective and immediate remedy to the affected landlord, and the prior decision in Jyoti Pershad did not decide the conflict created by the later amendments.

Conclusion: The Delhi Rent Control Act, 1958, as amended, prevails over the Slum Areas (Improvement and Clearance) Act, 1956, for proceedings under section 14A and Chapter IIIA, and prior permission under section 19 is not required.

Final Conclusion: The eviction proceedings were maintainable without obtaining permission from the competent authority, and the appeal failed.

Ratio Decidendi: Where a later special enactment contains an express overriding provision and creates an immediate statutory remedy, it prevails over inconsistent earlier provisions notwithstanding the earlier law's non obstante clause.

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