MANMOHAN KAUR vs SURYA KANT BHAGWANDI

The Supreme Court held that under Section 13 of the Bihar Buildings (Lease, Rent and Eviction) Control Act, 1982, a court must evaluate whether a tenant's delay in rent payment is adequately explained before striking off their defense. The Court emphasized that the Act aims to prevent unreasonable eviction of tenants and allows for judicial discretion in cases of justified delay. In this case, the Court found that the appellant had sufficiently explained the delay, thus reversing the lower courts' decisions that had led to a miscarriage of justice.