Santosh Mehta v. Om Prakash AIR 1980 SC 1644

it was pointed out that the provision contained in Section 15 (7) was a penal provision and in terms by the use of the word 'may' gave to the Controller a discretionary power in the matter of striking out of the defence and that, in appropriate cases, the Controller may refuse to visit upon the tenant the penalty of eviction for failure to pay or deposit the future rent.