GHANSHYAM DAS GUPTA vs DEVI LAL AND OTHERS

The Supreme Court held that the Bihar Buildings (Lease, Rent and Eviction) Act, 1947, specifically Section 11(1)(d), cannot be invoked for defaults in rent payment prior to the Act's applicability in the area. The Court clarified that even if a tenant offers rent which is refused by the landlord, the tenant must remit the rent by postal money order as per Section 13(1) to avoid eviction. The case was remitted to the lower court to determine if the tenant defaulted in rent payment during the applicable period post-Act extension.