Protected tenancy law: amended provisions applied when the landlord's right to possession arose after commencement.

The amended law governing protected tenancies applied where the landlord's notice was issued before the amendment but the notice period expired after it commenced. The right to possession arose only on expiry of the notice and termination of the tenancy, so no vested right existed before that date. The amendment did not invalidate the earlier notice; it regulated the landlord's enforceable claim to possession when that right accrued. Because the statutory scheme was tenant-protective, the law in force on the date the right to possession arose controlled the claim, and possession was not available under the unamended position.

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Issues: Whether the amending law governing protected tenancies applied where the landlord's notice was issued before the amendment but the tenancy expired after the amendment came into force.

Analysis: The right to terminate a protected tenancy was regulated by the notice procedure under Section 34, but the landlord's enforceable right to possession arose only when the notice expired and the tenancy stood terminated. The amendment did not invalidate notices already issued; it imposed an additional limitation on the landlord's right to obtain possession. Since no vested right to possession existed until the date of expiry of the notice, the amendment operating before that date governed the landlord's application. The statutory scheme, being protective of tenants, supported the construction that the law in force on the date of accrual of the right to possession controlled the claim.

Conclusion: The amended law applied because the notice period expired after the amendment came into force, and the landlord was not entitled to possession under the unamended position.

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