Prospective operation of rule amendments preserves existing deposit rights where no express retrospective effect is stated.

An amendment to Rule 9A of the Post Office Recurring Deposit Rules, 1981 was held not to apply to recurring deposit accounts opened before the amendment because the rule-making power under Section 15 of the Government Savings Bank Act did not authorise retrospective operation and the notification contained no express retrospective wording. The earlier rule, which allowed premature closure after one year, continued to govern those existing accounts, and a general undertaking to follow rules from time to time did not justify depriving depositors of accrued rights under concluded transactions. In the absence of clear retrospective language, amendments affecting existing statutory or contractual rights operate prospectively.

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Issues: Whether the amendment to Rule 9A of the Post Office Recurring Deposit Rules, 1981 could be applied retrospectively to recurring deposit accounts opened before the amendment so as to deny premature closure under the unamended rule.

Analysis: The source of rule-making power under Section 15 of the Government Savings Bank Act did not authorise retrospective operation, and the amending notification did not state that the change was retrospective. The deposits had been opened when the unamended rule permitted premature closure after one year, and the undertaking to abide by rules from time to time did not justify applying the amendment to existing accounts. Amendments are presumed to operate prospectively unless retrospectivity is expressly provided, particularly where the change affects existing rights under concluded transactions.

Conclusion: The amended Rule 9A did not govern deposits already opened under the unamended rule, and the petitioners remained entitled to premature closure in accordance with the earlier rule.

Ratio Decidendi: In the absence of express retrospective language, an amendment to a rule affecting existing contractual or statutory rights operates prospectively and cannot be applied to completed transactions already entered into under the unamended rule.

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