SMT. PUSHPA DEVI & ORS. vs MILKHI RAM

The Supreme Court held that under Section 2(h)(i) of the East Punjab Urban Rent Restriction Act, 1949, the term 'tenant' includes a person claiming to be a tenant, thereby allowing such individuals to tender rent arrears. The Court clarified that the existence of an admitted jural relationship of landlord and tenant is not necessary for the benefit of the proviso under Section 13(2)(i) to apply. Consequently, the Court allowed the appeal, overturning the lower courts' decisions that had dismissed the tender of rent as invalid due to the involvement of a disputed tenant.