Deepak Gopal Chaphekar vs . Dr. Ramesh Kumar Gulati on 4 October, 2012
(iii) the test may be illustrated by another example, water and
electricity charges, in fixed sum may be made part of the rent; where
there is no contract to pay the electric charges, they do not form part
of the rent. Where electric charges vary from month to month, then it
is not rent but if parties agreed to include a fixed amount of
electricity, that will be rent (reliance can be placed on Chhotey Lal vs.
Kewal Krishan Mehta AIR 1971 SC 987).