SUSHILA KASHINATH DHONDE & ORS. vs HARILAL GOVINDJI BHOGANI & ORS.

The Supreme Court held that under Section 28(1) of the Bombay Rents, Hotel and Lodging Houses Rates Control Act, 1947, it is not necessary for a relationship of landlord and tenant to exist for the Court of Small Causes to have jurisdiction over claims arising from the Act. The Court clarified that the deed of charge executed under Section 18(3) does give rise to claims under the Act, thus affirming the jurisdiction of the Small Causes Court. The appeal by the appellants was dismissed, upholding the lower courts' decrees in favor of the respondent.