Statutory finality under rent control law excludes a second revision under the Civil Procedure Code

The Kerala Buildings (Lease and Rent Control) Act, 1965 was treated as a self-contained code for eviction matters, providing an original forum before the Rent Control Court, an appeal under Section 18, and a revision under Section 20. Reading Section 18(5) with Section 20, the statutory scheme showed that the appellate decision was final except for the revision expressly provided by the Act. Once that statutory revision was exercised, a further revision under Section 115 of the Code of Civil Procedure was inconsistent with legislative intent and excluded by necessary implication, leaving the High Court without revisional jurisdiction on that footing.

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Issues: Whether, under the scheme of the Kerala Buildings (Lease and Rent Control) Act, 1965, a second revision under Section 115 of the Code of Civil Procedure, 1908 lay to the High Court after a revision had already been provided under Section 20 of the Act.

Analysis: The Act created a complete hierarchy for eviction matters, with the Rent Control Court as the original forum, an appeal under Section 18, and a revision under Section 20. Section 18(5) declared the appellate decision final and barred further challenge except as provided in Section 20. Reading Section 18(5) with Section 20, the scheme indicated that once the statutory revision had been exercised, a further revision under Section 115 of the Code of Civil Procedure, 1908 was inconsistent with the legislative intent and would defeat the finality built into the Act. The Act was treated as a self-contained code for the subject-matter, and the High Court's revisional jurisdiction under Section 115 stood excluded by necessary implication.

Conclusion: No second revision under Section 115 of the Code of Civil Procedure, 1908 lay to the High Court in such a case; the High Court had no jurisdiction to interfere on that footing.

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