Rent-control eviction jurisdiction cannot extend to title disputes or equitable relief beyond the statute's limits

In an eviction suit under the Bihar Building (Lease, Rent & Eviction) Control Act, 1982, the inquiry is confined to whether the statutory grounds for eviction, including a landlord-tenant relationship, are established. The court cannot expand that limited jurisdiction by examining title where concurrent findings show no such relationship exists. Order VII Rule 7 of the Code of Civil Procedure cannot be used to grant an equitable eviction decree on a basis not available under the special rent-control statute. The text emphasises that relief under a special enactment must remain within its statutory framework.

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Issues: Whether, in a suit for eviction under the Bihar Building (Lease, Rent & Eviction) Control Act, 1982, the court could go into the question of title and grant an equitable decree for eviction under Order VII Rule 7 of the Code of Civil Procedure, 1908.

Analysis: The suit was governed by a special rent-control enactment, and the decisive requirement for relief under it was the existence of a landlord-tenant relationship. The scope of inquiry was therefore confined to whether the statutory grounds for eviction were made out. Since both the trial court and the first appellate court had concurrently found that such relationship did not exist, a further enquiry into title was outside the limited jurisdiction exercised under the Act. Order VII Rule 7, which concerns the form and breadth of relief that may be granted on pleadings, could not be used to enlarge that limited statutory jurisdiction or to grant a decree on a ground not available under the Act.

Conclusion: The question of title could not be gone into in the eviction proceeding and an equitable decree under Order VII Rule 7 was not permissible; the remand order was unsustainable and the appellant succeeded.

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