NIRBHAI KUMAR vs MAYA DEVI .

The Supreme Court referred conflicting decisions in Martin & Harris Ltd. v. VIth Additional District Judge and Anwar Hasan Khan v. Mohd. Shafi to a larger bench, focusing on the interpretation of the proviso to Section 21(1)(a) of the U.P. Urban Buildings (Regulation of Letting, Rent and Eviction) Act, 1972. The Court established that the protections under this proviso are personal to the tenant and can be waived, emphasizing that the proceedings are not of public nature but rather personal disputes between landlords and tenants. The matter was thus placed before a larger bench for authoritative clarification.