V. K. A. RANGANATHA KONAR vs THE TIRUCHIRAPPALLI MUNICIPAL COUNCIL, BY ITSCOMMISSIONER,

The Supreme Court held that under Section 4(4) of the Madras City Tenants’ Protection Act, 1921, the landlord must pay compensation for improvements within three months of the decree, failing which the suit stands dismissed. The Court found that the High Court erred in interpreting Section 4(1) as controlling Section 4(4), emphasizing that the mandatory nature of Section 4(4) must be upheld. Consequently, the Court reinstated the trial court's dismissal of the landlord's suit due to non-compliance with the statutory time frame for payment.