Company Court jurisdiction in liquidation extends to landlord possession claims despite rent control law; eviction grounds may still be examined.

Section 446 of the Companies Act gives the Company Court wide jurisdiction over proceedings against a company in liquidation, including a landlord's claim for recovery of possession from the Official Liquidator, to avoid multiplicity of proceedings and protect company assets. The existence of the Delhi Rent Control Act does not by itself oust that jurisdiction where eviction-related possession is sought in liquidation. The Court may still consider whether a statutory ground for eviction under the rent law exists and whether the premises are genuinely required by the liquidator. The application was held maintainable before the Company Court, and the challenge to the possession order failed.

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Issues: Whether an application by the landlord for recovery of possession of premises in the tenancy of a company under winding up was maintainable before the Company Court under Section 446 of the Companies Act, and whether the Company Court could examine the claim for eviction with reference to Section 14 of the Delhi Rent Control Act.

Analysis: Section 446 confers wide jurisdiction on the Company Court over proceedings against the company in liquidation and is intended to prevent multiplicity of proceedings and protect the assets of the company. A landlord's request for possession of premises in the hands of the Official Liquidator falls within that jurisdiction. The Court may examine whether the premises are genuinely required by the liquidator and whether a statutory ground for eviction exists under the rent law, but the mere existence of the Delhi Rent Control Act does not oust the Company Court's jurisdiction where the company is in liquidation and the matter concerns recovery of possession from the liquidator.

Conclusion: The application was maintainable before the Company Court, and the appeal against the order directing recovery of possession failed.

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