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Issues: Whether the amending provisions introduced by Bombay Act XXXIII of 1952 applied to the pending tenancy so as to require a fresh valid notice before the landlord could seek ejectment.
Analysis: The earlier tenancy had already been statutorily extended once under the 1939 Act, and the 1952 amendment further extended the tenancy period and imposed new conditions for termination. The decisive date was not the date on which the landlord gave an earlier notice, but the date on which the tenancy would otherwise have expired and the right to recover possession would accrue. Since the amendment came into force before that accrual date, it governed the landlord's right to terminate and obtain possession. The change was treated as operating on future rights under existing tenancies and not as an impermissible retrospective alteration of the past.
Conclusion: The amending provisions applied, the earlier notice was insufficient, and the landlord was not entitled to eject the tenants without complying with the statutory notice requirements.