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Issues: Whether, after the amendment substituting the District Judge for the High Court as the revisional authority under Section 25 of the Small Cause Courts Act, an application for revision filed in the High Court remained maintainable in respect of a decree passed before the amendment came into force.
Analysis: The amendment took effect on the date of its publication and contained no saving provision preserving the High Court's revisional power for pending or prior matters. The right of revision was treated as a matter of jurisdiction vested in the court, not as an accrued or vested right of the suitor in the particular forum. Section 6 of the U.P. General Clauses Act was applied on the footing that an amendment operates through repeal and re-enactment, but the applicant acquired no vested right to invoke the High Court's supervisory jurisdiction. The amendment therefore shifted the forum for revision to the District Judge without giving the legislation retrospective effect.
Conclusion: The revision application in the High Court was not maintainable and was rightly rejected.
Ratio Decidendi: Where an amendment withdraws revisional jurisdiction from one court and confers it on another, no vested right accrues to a litigant to insist on the earlier forum unless the statute preserves that right.