CA 17 July 1989. Considered whether the respondents, Curtis (C) underlessees, failed to qualify for enfranchisement because the amended proviso of the Leasehold Reform Act 1967 s3(1) precluded their underlease from being treated as a long tenancy . The amendment, introduced by the Housing Act 1980 , was intended to cut down its scope. Previous case had gone in favour of C. C`s underlease contained a royal lives clause which Proma Ltd (P) considered defeated C`s qualification for enfranchisement . C`s underlease was granted in 1982, after the amendment in 1980 which prevented enactment of the royal lives clause on tenancies after that date. P claimed that the underlease was granted in pursuance of a contract entered into before 1980. The original building lease from 1972 made express provision for the granting of tenancies based on this lease and containing the royal lives clause. There was however no obligation to grant underleases. As a result of this the CA found it impossible to s