MIRAN DEVI vs BIRBAL DASS

The Supreme Court interpreted Section 4(2)(a) of the East Punjab Urban Rent Restriction Act, 1949, clarifying that the phrase 'in similar circumstances' applies to both 'the same' and 'similar accommodation'. The Court held that the prevailing rent before January 1, 1939, can only be considered for fixing basic rent if the building existed under similar circumstances at that time. Additionally, it ruled that general development of the locality does not constitute a change in circumstances sufficient to alter the application of Section 4(2)(a). The appeal was dismissed, upholding the lower court's decision on fair rent fixation.