Independent rent-enhancement remedy survives deletion of release grounds, while supervisory review cannot set rent without evidence.

Deletion of the former exceptional release grounds in the Explanation to Section 21(1) does not extinguish the independent rent-enhancement mechanism in the proviso to Section 21(8). Although landlords can no longer seek release on the omitted grounds, applications to enhance rent against specified public tenants remain maintainable. Supervisory jurisdiction under Article 227 is exceptional and confined to correcting jurisdictional error, failure to exercise jurisdiction, or grave injustice; it is not a substitute for the statutory authority's fact-based assessment. Rent cannot be enhanced on an unsupported assertion about adjoining premises, and the competent Rent Control Authority must determine the quantum afresh on evidence from the original application date.

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Issues: (i) Whether deletion of clauses (ii) and (iv) of the Explanation to Section 21(1) affects the landlord's right to seek rent enhancement under the proviso to Section 21(8); (ii) Whether the High Court could, in exercise of supervisory jurisdiction under Article 227, itself determine and enhance rent without supporting material on record.

Issue (i): Whether deletion of clauses (ii) and (iv) of the Explanation to Section 21(1) affects the landlord's right to seek rent enhancement under the proviso to Section 21(8).

Analysis: Section 21(8) excludes the bona fide requirement ground against specified public tenants, while its proviso provides an independent mechanism for enhancement of rent. Following the omission of the two exceptional grounds formerly contained in the Explanation, the landlord cannot seek release on those grounds; however, the statutory rent-enhancement remedy remains operative. Construing the proviso as inoperative would leave the landlord without either a means of recovery of possession or financial recompense.

Conclusion: Deletion of clauses (ii) and (iv) does not affect the operation of the proviso to Section 21(8), and an application for enhancement of rent under that proviso is maintainable.

Issue (ii): Whether the High Court could, in exercise of supervisory jurisdiction under Article 227, itself determine and enhance rent without supporting material on record.

Analysis: Supervisory jurisdiction may be exercised in exceptional rent-control matters to correct jurisdictional excess, failure to exercise jurisdiction, or grave injustice, but it is not appellate power and cannot ordinarily substitute the High Court's determination for that of the statutory authority. The enhanced rate adopted by the High Court rested on an unsubstantiated assertion regarding rent of adjoining premises, without material establishing that rate.

Conclusion: The High Court could exercise Article 227 jurisdiction only exceptionally, but its enhancement of rent on the material available was unsustainable; the rent determination requires fresh adjudication by the Rent Control Authority.

Final Conclusion: The statutory remedy for rent enhancement remains available to the landlord, while the quantum of rent must be determined afresh by the competent authority on an evidentiary basis, with effect from the original application date.

Ratio Decidendi: Omission of statutory exceptions concerning release of premises does not impliedly extinguish an independent proviso authorising rent enhancement, and Article 227 cannot be used to supplant a statutory authority's fact-dependent determination without evidentiary foundation.

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