MOHD. MAHMOOD AND ANOTHER vs TIKAM DAS AND ANOTHER

The Supreme Court held that under Section 45(1) of the Madhya Pradesh Accommodation Control Act, 1951, no civil court has jurisdiction to entertain a suit regarding matters that the Rent Controlling Authority is empowered to decide. The Court affirmed that the lawfulness of a sub-tenancy must be determined by the Rent Controlling Authority as per Section 15(3), and thus the High Court's dismissal of the appellants' suit was correct. The Court clarified that even if a landlord has obtained a decree against a tenant, sub-tenants can still seek a determination of their lawful tenancy status from the Rent Controlling Authority.