Expanded Small Causes jurisdiction governs pending rent and eviction suits; court losing jurisdiction cannot decide them.

The U.P. Civil Laws (Amendment) Act, 2015 enlarged the pecuniary jurisdiction for rent and eviction suits to buildings valued up to Rs. 1,00,000, and the amended text was applied to pending matters as well as fresh filings. The plain wording of the amendment was treated as controlling, so the statement of objects and reasons did not limit its scope. On that basis, suits within the revised valuation fell within the Small Causes Court presided over by the Civil Judge, Senior Division, and a court that had ceased to have jurisdiction could not continue to decide them. A suit valued at Rs. 44,000 was therefore outside the Additional District Judge's jurisdiction and had to be dealt with by the proper Small Causes Court.

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Issues: (i) Whether, after the U.P. Civil Laws (Amendment) Act, 2015, suits for rent and eviction from a building valued up to Rs. 1,00,000 were triable by the Civil Judge, Senior Division, notwithstanding that the suit had been instituted earlier. (ii) Whether the Additional District Judge had jurisdiction to decide a Small Causes suit of valuation Rs. 44,000 after the amendment came into force.

Issue (i): Whether, after the U.P. Civil Laws (Amendment) Act, 2015, suits for rent and eviction from a building valued up to Rs. 1,00,000 were triable by the Civil Judge, Senior Division, notwithstanding that the suit had been instituted earlier.

Analysis: The amended Section 15 of the Provincial Small Cause Courts Act, 1887, as applicable in Uttar Pradesh, expanded the pecuniary jurisdiction for rent and eviction suits to Rs. 1,00,000. The language of the amending provision was treated as clear and unambiguous, and the statement of objects and reasons was held not to control the plain text. The change in pecuniary jurisdiction was held to govern trial as well as institution, and to operate on pending matters as well.

Conclusion: The amendment applied to the suit and such suits up to Rs. 1,00,000 were triable by the Civil Judge, Senior Division.

Issue (ii): Whether the Additional District Judge had jurisdiction to decide a Small Causes suit of valuation Rs. 44,000 after the amendment came into force.

Analysis: Once the amended jurisdictional threshold became operative, suits of this class and valuation fell within the Small Causes Court presided over by the Civil Judge, Senior Division. Section 17 of the Bengal, Agra and Assam Civil Courts Act, 1887 was relied upon to hold that a court which had ceased to have jurisdiction could not continue to decide such matters. The suit valuation being Rs. 44,000 placed it within the amended jurisdiction of the Civil Judge, Senior Division, not the Additional District Judge.

Conclusion: The Additional District Judge lacked jurisdiction to decide the suit.

Final Conclusion: The impugned judgment was set aside and the matter was remanded to the regular Small Causes Court for fresh decision in accordance with law, with pending rent and eviction suits of the relevant category directed to be transferred to the proper Small Causes Court.

Ratio Decidendi: Where a statutory amendment plainly enlarges the pecuniary jurisdiction of the Small Causes Court, the amended jurisdiction governs pending rent and eviction suits of the covered class, and a court that has ceased to have jurisdiction cannot validly decide them.

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