Prospective amendment and landlord status principles preserved pending eviction proceedings and supported maintainability under the Act.

A prospective amendment excluding premises of religious or charitable institutions from the Act did not invalidate pending eviction proceedings or divest the original forum of jurisdiction, because a change of forum ordinarily does not affect existing actions absent express or clearly implied legislative intent. The text also states that a person who receives rent as landlord can maintain eviction proceedings under the statutory definition of landlord, and ownership is not a necessary precondition where landlord status is otherwise established. On that basis, the eviction decree was affirmed and both the jurisdictional objection and the challenge to maintainability failed.

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Issues: (i) whether the 1994 amendment excluding premises of religious or charitable institutions from the Act defeated the pending eviction proceedings on the ground of want of jurisdiction in the forum; (ii) whether a person claiming to be the owner, but admittedly receiving rent as landlord, could maintain eviction proceedings under the Act.

Issue (i): whether the 1994 amendment excluding premises of religious or charitable institutions from the Act defeated the pending eviction proceedings on the ground of want of jurisdiction in the forum.

Analysis: The amendment was prospective and did not contain any indication that pending actions were to be transferred or invalidated. A change in forum does not ordinarily affect pending proceedings unless the statute expressly so provides or by necessary implication shows that result. The proceedings before the original forum had already been concluded when the amendment came into force, and the objection to jurisdiction was also raised belatedly.

Conclusion: The amendment did not nullify the pending proceedings or deprive the forum of jurisdiction in the manner contended.

Issue (ii): whether a person claiming to be the owner, but admittedly receiving rent as landlord, could maintain eviction proceedings under the Act.

Analysis: The statutory definition of landlord includes a person receiving or entitled to receive rent on his own account or on behalf of another. A petition for eviction under the relevant provision can be maintained by a landlord, and ownership is not a necessary precondition where landlord status is otherwise established. A claimant asserting a larger right is not barred from obtaining relief if the lesser right relied upon is legally sufficient.

Conclusion: The eviction petition was maintainable because the respondent was a landlord within the statutory definition.

Final Conclusion: The appeal failed on both the jurisdictional challenge and the challenge to the respondent's competence to seek eviction, and the eviction decree stood affirmed.

Ratio Decidendi: A prospective amendment effecting a change in forum does not affect pending proceedings absent express or clearly implied legislative intent, and a statutory landlord who receives rent may maintain eviction proceedings even if he also asserts a higher title.

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