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Issues: Whether the rent control proceedings could be stayed under Section 10 of the Code of Civil Procedure, 1908, or under the inherent powers under Section 151 of the Code of Civil Procedure, 1908, pending disposal of the specific performance suit.
Analysis: Section 10 applies only where the previously and subsequently instituted matters are suits and the courts are of concurrent jurisdiction. A rent control proceeding is not a suit, and the Rent Controller cannot invoke Section 10 CPC to stay proceedings before him. Even on the footing that inherent powers could be considered, the scope of the two proceedings was materially different. The suit concerned the genuineness of the agreement of sale and the question whether the respondents were bona fide purchasers without notice, whereas the rent control case concerned wilful default and bona fide requirement, with the Rent Controller being confined to examining whether the tenants' denial of title was bona fide. The summary nature of rent control jurisdiction and the statutory mechanism in cases of denial of title left no basis to hold the eviction proceeding in abeyance merely because a civil suit was pending. No prejudice to the petitioner was shown, as recovery of possession could follow the civil decree if obtained.
Conclusion: The request to stay the rent control proceedings was not sustainable, and the revision failed.