KALURAM ONKARMAL AND ANOTHER vs BAIDYANATH GORAIN

The Supreme Court held that under Section 17(1) of the West Bengal Premises Tenancy Act, 1956, a tenant must pay rent in court after a suit for eviction is filed, regardless of prior deposits made with the Rent Controller under Section 21. The Court affirmed that Section 17(1) is a self-contained scheme that governs the landlord-tenant relationship during litigation, and the majority view in Siddheswar Paul v. Prakash Chandra Dutta was upheld. Consequently, the tenant's defense could be struck off for failing to comply with the court payment requirement, leading to the dismissal of the appeal.