Construction of "rent" under the Bengal Tenancy Act includes rent in kind, and legislative history cannot narrow the statutory text.

Section 50 of the Bengal Tenancy Act was construed consistently with the Act's definition of "rent" in Section 3(5), so the statutory presumption applied to rent payable in money, in kind, or partly in both forms. The Court held that the term could not be confined to cash rent merely because of legislative history, and that Select Committee proceedings could not be used to cut down the plain meaning of the enacted text. On that construction, tenants were entitled to the benefit of Section 50 and the contrary view taken below was rejected.

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Issues: (i) Whether the term "rent" in Section 50 of the Bengal Tenancy Act includes rent payable partly or wholly in kind; (ii) Whether the Report of the Select Committee could be used to restrict the scope of Section 50.

Issue (i): Whether the term "rent" in Section 50 of the Bengal Tenancy Act includes rent payable partly or wholly in kind.

Analysis: Section 50 had to be read with Section 3(5), which defined rent as whatever is lawfully payable or deliverable in money or kind by a tenant to the landlord for use or occupation of the land. That definition was not repugnant to Section 50. The statutory presumption in Section 50, therefore, applied not only to money rents but also to rents payable partly in cash and partly in kind, or entirely in kind.

Conclusion: The term "rent" in Section 50 includes rent payable in kind, whether wholly or partly, and the tenants were entitled to the benefit of the section.

Issue (ii): Whether the Report of the Select Committee could be used to restrict the scope of Section 50.

Analysis: The Court held that reference to legislative proceedings and Select Committee reports is not permissible as an aid to construction. The omission of a proposed clause did not justify narrowing the plain meaning of the enacted words, especially where the Act itself contained a comprehensive definition of rent. The legislative history could not override the statutory text.

Conclusion: The Report of the Select Committee could not be relied on to confine Section 50 to money rents.

Final Conclusion: The statutory presumption under Section 50 operated on the facts of these cases, the contrary view of the courts below was rejected, and the appeals succeeded with costs.

Ratio Decidendi: Where a statute defines "rent" to include payment in money or kind, a provision using that term must be construed consistently with the definition, and legislative history cannot be used to cut down the plain statutory meaning.

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