If a question arises whether the withholding of a consent required by virtue of section 97 (landlord's consent to improvements) was unreasonable, it is for the landlord to show that it was not.
In determining that question the court shall, in particular, have regard to the extent to which the improvement would be likely—
A consent required by virtue of section 97 may be validly given notwithstanding that it follows, instead of preceding, the action requiring it.
Where a tenant has applied in writing for a consent which is required by virtue of section 97—