Retrospective rent-control application cannot invalidate a civil court decree for possession when the suit was filed earlier.

Where a rent-control statute applied to an area only after the suit was filed, the later notification did not retrospectively divest the civil court of jurisdiction or invalidate a decree already passed. In the absence of any express or implied provision barring pending suits or making the enactment retrospective, the parties' rights crystallised on the date of institution of the suit and the civil court's decree for possession remained valid and executable. The appeals therefore failed.

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Issues: Whether a decree for possession passed by the civil court after the Rajasthan Rent Control Act, 2001 became applicable to the area could be treated as invalid or inexecutable when the suit had been filed before the notification bringing the area within the Act.

Analysis: The applicable statutory scheme made the Rent Tribunal the forum for landlord-tenant disputes only in areas to which the Act extended, but it contained no express or implied provision invalidating suits already instituted before the notification or depriving the civil court of power to decide such pending suits. The Court distinguished precedents where the rent legislation expressly barred execution of decrees or expressly governed pending matters, and relied on the settled principle that the rights of the parties ordinarily crystallise on the date of institution of the suit. Since the suit for possession was filed before the Act became applicable to the area, the later notification did not retrospectively take away the civil court's jurisdiction or render the decree void.

Conclusion: The decree passed by the civil court was valid and executable, and the appeals failed.

Ratio Decidendi: In the absence of an express or implied statutory provision making a rent-control enactment retrospective or barring pending civil suits and decrees already validly obtained, the law applicable on the date of institution of the suit governs the parties' rights and the civil court's decree remains valid.

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