SHRI VIDYA PRACHAR TRUST vs PANDIT BASANT RAM

The Supreme Court ruled that a deposit made under Section 31 of the East Punjab Relief of Indebtedness Act, 1934 does not constitute a valid tender of rent under Section 13 of the East Punjab Urban Rent Restriction Act, 1949. The Court clarified that Section 31 is designed for debtor-creditor relationships and does not apply to landlord-tenant situations. Consequently, the tenant's reliance on the deposit to avoid eviction for non-payment of rent was rejected, affirming the lower courts' decisions.