Strict compliance with rent deposit procedure governs default disputes; deposit under another statute does not cure tenant default.

A rent control statute prescribing the mode of payment, tender and deposit of rent requires strict compliance: where the landlord refuses rent, the tenant must deposit it in the manner and before the authority specified by the Act. A deposit made under a different enactment does not satisfy that statutory requirement and cannot defeat eviction for default. The text also notes that supervisory interference under Article 227 is permissible where the rent authorities commit a serious error of law by treating an invalid deposit as compliance, since that amounts to failure to exercise jurisdiction according to law.

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Issues: (i) Whether deposit of rent made under the Punjab Relief of Indebtedness Act, 1934 could be treated as valid payment or tender under the Delhi Rent Control Act, 1958 so as to avoid eviction for default in payment of rent; (ii) Whether the High Court was justified in interfering under Article 227 of the Constitution of India with the concurrent findings of the rent authorities.

Issue (i): Whether deposit of rent made under the Punjab Relief of Indebtedness Act, 1934 could be treated as valid payment or tender under the Delhi Rent Control Act, 1958 so as to avoid eviction for default in payment of rent.

Analysis: The Delhi Rent Control Act, 1958 prescribes a specific method for payment, tender and deposit of rent. Where the landlord does not accept rent, the tenant must act strictly in accordance with Section 27 and deposit the rent before the Controller in the prescribed manner with the required particulars. A deposit made elsewhere under a different statute does not satisfy the statutory requirement. The earlier decision relied upon by the tenant was held distinguishable because the procedural setting and the statutory scheme were different. In rent control matters, the tenant can claim the statutory benefit only by strict compliance with the conditions laid down by the Act.

Conclusion: The deposit under the Punjab Relief of Indebtedness Act, 1934 was not a valid tender or deposit under the Delhi Rent Control Act, 1958, and the tenant was in default.

Issue (ii): Whether the High Court was justified in interfering under Article 227 of the Constitution of India with the concurrent findings of the rent authorities.

Analysis: The High Court interfered not with a mere finding of fact, but because the authorities below had committed a serious error of law by treating an invalid deposit as sufficient compliance with the Act. Such an error resulted in failure to exercise jurisdiction according to law. In that situation, supervisory interference under Article 227 was permissible.

Conclusion: The High Court's exercise of jurisdiction under Article 227 was upheld.

Final Conclusion: The appeal failed because the tenant did not comply with the statutory mode of deposit required by the rent control law, and the High Court's supervisory interference was sustained.

Ratio Decidendi: Where a rent control statute prescribes an exclusive procedure for payment or deposit of rent, strict compliance with that procedure is mandatory, and a deposit made under another enactment cannot displace the tenant's default.

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