JAMIA MILLIA ISLAMIA

FACULTY OF LAW

ADMINISTRATIVE LAW

JUDICIAL REVIEW OF DELEGATED LEGISLATION

SUBMITTED TO-

PROF. Dr ALISHA KHATUN

SUBMITTED BY-

MOHD KAMRAN ANSARI

B.A.LLB. (Hons.) (REGULAR) VI Sem.

STUDENT ID: 202004054

ROLL No.: 40

BATCH- 2020- 2025

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TABLE OF CONTENTS

INTRODUCTION......................................................................................................................2

FORMS OF DELEGATED LEGISLATION............................................................................4

ADVANTAGES OF DELEGATED LEGISLATION..............................................................4

CRITICISM OF DELEGATED LEGISLATION.....................................................................5

FACTORS RESPONSIBLE FOR THE RAPID GROWTH OF DELEGATED

LEGISLATION..........................................................................................................................5

JUDICIAL CONTROL OF DELEGATED LEGISLATION....................................................7

I. Substantive Ultra Vires...................................................................................................8

II. Procedural Ultra Vires...............................................................................................10

CONCLUSION........................................................................................................................13

BIBLIOGRAPHY....................................................................................................................15

INTRODUCTION
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 “Delegated Legislation is an excuse for the legislation, a shield for the executive and a
provocation for the Constitutional jurists.” – P.B. Mukherjee J.

Montesquieu, a French scholar, propounded the theory of separation of powers. According to

this theory, three organs (i.e.) the legislature, the executive and the judiciary should perform
their functions independently and no organ should interfere in the work of the other organ.
However, the Indian Constitution does not strictly follow this theory. According to the Indian
Constitution, the legislature has the power to make laws, the executive is responsible for the
execution of laws and the judiciary has the power to solve disputes and to deliver justice. Due
to increased legislative activities, it is becoming difficult for the legislature to legislate on
every matter. Therefore, the concept of Delegated legislation has come up. Delegated
legislation is a process where the executive authority is given the power by the legislature to
make laws in order to implement and administer the requirements of the primary legislation.

Delegation of powers means the powers passed on by the higher authority to the lower
authority to make laws. Delegated legislation means the powers given by the legislature to
the executive or administration to enact certain laws.

The concept of delegated legislation is not mentioned under Indian Constitution but it can be
understood by interpreting Article 321 of the Constitution. According to this article, Rajya
Sabha can open a new branch of All India Service after getting 2/3 votes. According to this,
some powers of the legislature will be delegated to the recruiters of All India Service. One of
the most important cases relating to delegated legislation in India is D.S. Grewal v. State of
Punjab1. In this case, the constitutionality of the All India Service Act, 1951 was challenged.
D.S. Grewal was appointed to the All-India Service and posted to Punjab. He was the
Superintendent of Police of various districts. In 1957, he was appointed as Assistant
Superintendent of Police. In 1958, he was posted to Dharamsala. After a few months, an
action was taken against him under Rule 5 of All India Services (Discipline and Appeal)
Rules, 1955. An enquiry committee was set up which was led by Shri K.L. Bhudiraja. He
filed a petition under Article 226 of the Indian Constitution before the Punjab & Haryana
High Court in which he challenged the constitutionality of the Act and the legality of the
enquiry against him.

The Supreme Court held that Article 312 of the Indian Constitution deals with the power of
delegated legislation. As the case was very serious therefore the petitioner can be removed or

1
AIR 1959 SC 512.

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compulsorily removed from his post by the government. Justice K.N. Wanchoo observed that
“There is nothing in the words of Article 312 which takes away the usual power of
delegation, which ordinarily resides in the legislature.” The English Law allows the
Parliament to delegate any amount of power without any restriction. Whereas, the position in
America and India is different where the governments do not have unlimited power. They can
delegate power only in a controlled manner with certain restrictions.

FORMS OF DELEGATED LEGISLATION

Delegated Legislation may take several forms. They may be normal or of exceptional type,
they may be usual or unusual, positive or negative, skeleton or Henry VIII Clause. Broadly
Speaking, delegated legislation may be classified on the following principles:

 Title Based Classification: Delegated Legislation may be in the forms of Rules,

Bye-Laws, Notifications, Schemes, Orders, Ordinances, Directors, etc.
 Discretion Based Classification: A discretion may be conferred on the executive to
bring the Act into operation of certain conditions. Such legislation is called
“conditional” or “contingent” legislation.
 Purpose Based Classification: A classification may be based on the nature and
extent of power conferred and the purposes for which powers can be exercised. Thus,
the executive can be empowered to fix the appointed day of the Act to come into
force, to supply details, to extend the provisions of the Act to other areas, to include
or to exclude the operation of the Act in certain territories. Persons, industries,
commodities. To suspend or to modify the provisions of the Act, etc.
 Authority Based Classification: A statute may also empower the executive to
delegate further powers conferred on it to its subordinate authority. This is known as
“sub-delegation.”

ADVANTAGES OF DELEGATED LEGISLATION

 Saves time for the legislature.

 Allows for flexibility.
 Expert opinion is required in legislation.
 Parliament is not always present in the session.

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  Used as an experimental basis.
 It is restored to use in a situation of emergency.
 Can be easily settled down by consulting the required party of the case.

CRITICISM OF DELEGATED LEGISLATION

 It has a long duration of bearing for legislative control because the legislature is the
supreme organ of the state as it consists of three main organs which are: Judiciary,
Legislative and Executive.
 All of them must work with or in relation to each other and it should be done in a
balanced way on the basis of power given to each organ for working effectively.
Instead of various advantages, delegated legislation has weakened the legislative
control executive.
 The executive has become stronger with delegated legislation, it can easily encroach
the rules and regulations of legislation by making rules.
 This concept opposes the rule of Separation of Power.
 Lack of relevant discussion before framing the law.
 It is not in acceptance with the principle of Rule of Law.
 It is not stable in nature, it keeps on fluctuating on the ground of Political changes.

FACTORS RESPONSIBLE FOR THE RAPID GROWTH OF DELEGATED

LEGISLATION

The Indian Constitution has established a Welfare State 2 which mandates that the State shall
legislate on innumerable activities touching human lives in order to promote the ‘maximum
happiness of the maximum number of people.’3 Consequently, the State has to undertake
legislation on a variety of subjects. Given this increasing legislative activity, the legislatures
will not find adequate time to legislate on every minute detail and limit themselves to ‘policy
matters and leaving a large volume of area for executives to frame rules to carry out the
purposes of legislation.’ Thus, the need for delegation became indispensable and sought to be
justified on the grounds of ‘speed, flexibility and adaptability.’4

2
Bharat Bank Vs. Employees of Bharat Bank, AIR 1950 SC, P.306. See the observations of Justice Mukherjee.
3
Bentham’s Theory of Utility. “Theory of Legislation”.
4
Erskire May, Parliamentary Practice 24th Edition Lexis Nexis.

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The application of law to changing circumstances was made feasible through the instruments
of ‘rules’ framed by the executive. It is not a surprise to find that during the years (1973-77)
spanning a period of 4 years Parliament enacted 300 statutes but the rules framed by the
executive exceeded 25000.5 The following are the significant reasons for the growth of
Delegated Legislation in India:

 Pressure on Parliament: The number of activities in states is expanding which

requires law and it is not possible for the Parliament to devote sufficient time to every
matter. Therefore, for this, the Parliament has made certain policies which allow the
executives to make laws accordingly.
 Technicality:  Sometimes there are certain subject matters which require technicality
for which there is a requirement of experts who are professional in such fields and
members of Parliament are not experts in such matters. Members of Parliament may
be the best politicians but they are not experts to deal with highly technical matters
which are required to be handled by the experts.6 Therefore, experts are given such
powers to deal with technical problems like gas, atomic, energy, drugs, etc.
 Flexibility: It is not possible for the Parliament to look after each contingency while
passing an enactment; for this, certain provisions must be added. But the process of
amendment is very slow as well as cumbersome process. Thus, the process of
delegated legislation helps the executive authority to make laws according to the
situation. In the case of bank rates, policy regulation, etc., they help a lot in forming
the law.
 Emergency: At the time of emergency, it is not possible for the legislative to provide
an urgent solution to meet the situation. In such cases, delegated legislation is the only
remedy available. Therefore, in times of war or other national emergencies, the
executives are vested with more powers to deal with the situation.
 The complexity of modern administration: With the increasing complexity of
modern administration and the functions of the state being expanded and rendered to
economic and social spheres too, there is a need to shift to new reforms and provide
more powers to different authorities on some specific and suitable occasions.

5
Jain, M.P. & Jain, S.N.; Principles of Administrative Law, 6th Ed., Vol. II, Wadhwa Nagpur, 2007.
6
Arvind Kurian Abraham, Delegated Legislation: The Blindspot pf the Parliament, available at:
https://thewire.in/government/delegated-legislation-parliament-executive

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  Local Matters: Delegated Legislation helps to deal with local matters. For Example,
District Magistrate is given the power to make laws to maintain law and order in the
district.
 Unforeseen Contingencies: Delegated legislation also helps to deal with unforeseen
contingencies. It provides for the power of constant adoption to unknown future
conditions without the necessity of amending the legislation.

And so, therefore for immediate and suitable actions to be taken there has been an immense
growth of delegated legislation in every country and being that important and useful it
becomes a non-separable part in the modern administrative era.

JUDICIAL CONTROL OF DELEGATED LEGISLATION

Legislatures having delegated their powers must bear the responsibility to ensure that the
delegatee shall not over-step the legitimate domain and commit a violation by exceeding or
abusing the powers delegated.7 Thus, the legislatures have to control the delegated legislation
and if not, executives may exercise the delegated power to become a potential dictator or
even become a parallel legislature.

This legislative control over delegated legislation has become a ‘living continuity as a
constitutional necessity.’8 The rule of the majority in democratic systems has virtually made
legislative controls ineffective. A similar statement is found in Wade & Forsyth. 9 A more
serious observation has been made by Mr. Lloyd George to the effect that ‘legislatures have
no control over the executive.” All these observations are pointers to the view that had the
Parliamentary control over delegated legislature been effective, the need for judicial control
would not have arisen or probably reduced to the minimum. This has not been so, hence,
judicial control has become an inevitable necessity to prevent executives acting as super-
legislatures or potential dictators.10

Delegated Legislation does not fall beyond the scope of judicial reviewand in almost all
democratic countries it is accepted that courts can decide the validity or otherwise of
delegated legislation mainly by applying tw tests:

7
Jain, M.P. & Jain, S.N.; Principles of Administrative Law, 6th Ed., Vol. II, Wadhwa Nagpur, 2007.
8
See, Justice Krishna Iyer’s Observation in Arvind Singh’s case. (AIR 1979 SC).
9
See, ‘Administrative Law’ (2009) 764-765.
10
C.K. Takwani, Lectures on Administrative Law, 4th Edition (2010).

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 I. Substantive Ultra Vires
II. Procedural Ultra Vires

Ultra Vires means means ‘beyond the authority’ or ‘lack of power’. An act may be said to be
ultra vires when it has been done by a person or a body of persons which is beyond his
authority or jurisdiction.11

I. Substantive Ultra Vires

When an Act of legislation enacts in the excess of power, conferred on the Legislature by the
Constitution, the legislation is said to be ultra vires the Constitution. On the same principle,
when a subordinate legislation goes beyond what the delegate is authorised to enact (and
exceeds its power conferred on it by the Legislature), it acts ultra vires.12 This is known as
substantive ultra vires. Substantive ultra vires means that the delegated legislation goes
beyond the scope of the authority conferred on it by the parent statute or by the Constitution.

Power delegated by statute is limited by its terms and subordinate to its objects. The delegate
must act in good faith, reasonably, infra vires the power granted and on relevant
considerations. All his decisions, whether characterised as legislative, administrative or
quasi-judicial, must be in harmony with the Constitution and other laws of the land. They
must be reasonably related to the purposes of the enabling legislation. If they are manifestly
unjust or oppressive or outrageous or directed to an unauthorised end or do not tend in some
degree to the accomplishment of the objects of delegation court might well say, “Parliament
never intended to give authority to make such rules; they are unreasonable and ultra vires.”13

A delegated legislation may be held to be invalid on the ground of substantive ultra vires in
the following circumstances:

1. Where parent Act is unconstitutional: If the delegating statute itself is ultra vires
the Constitution and is bad for that reason, delegated legislation also is necessarily
bad. In Chintananrao V. State of M.P.,14 the parent Act authorised the Deputy
Commissioner to prohibit the manufacture of bidis in some areas during certain
periods. The order passed by the Deputy Commissioner under the Act was held ultra
vires inasmuch as the Act under which it was made violated the Fundamental Right to

11
Concise Oxford English Dictionary, (2002); P.R. Aiyar, Advanced Law Lexicon (2205) Vol. IV.
12
Sir W. Graham cited by Griffith: Delegated Legislation, Some Recent Developments, (1949) 12 Mod LR 297.
13
Sitaram Sugar Co. Ltd. v. Union of India, (1990) 3 SCC 223.
14
AIR 1951 SC 118.

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 carry on any occupation, trade or business, guaranteed by Article 19(1 )(g) of the
Constitution of India.15
2. Where delegated legislation is inconsistent with the Parent Act: It is an accepted
principle that delegated authority must be exercised strictly within the authority of
law. Delegated legislation can be held valid only if it conforms exactly to the power
granted. In Chester v. Bateson,16 a regulation issued under the parent Act prohibited a
landlord from having access to courts to recover possession of a dwelling, occupied
by a war-worker, except with the consent of a Minister and imposed penalty for
taking such proceedings. The court held the regulation illegal as it deprived the King's
subjects of their right of access to the Courts of Justice and rendered them liable to
punishment in case they had the temerity to ask for justice in any of the King's
Courts.17
This principle is accepted in India also. In Chandra Bali v. R,18 the validity of certain
rules framed under the Northern India Ferries Act, 1878 was questioned. The Act
authorised the making of rules for the purpose of maintaining order and ensuring the
safety of passengers and property. The delegate, however, framed rules forbidding the
establishment of private terries within a distance of two miles from the boundaries of
another ferry. The court held that the rules were outside the scope of the delegated
power and therefore ultra vires.
3. Where delegated legislation is unconstitutional: Sometimes a parent Act or
delegating statute may be constitutional and valid and delegated legislation may be
consistent with the parent Act, yet the delegated legislation may be held invalid on the
ground that contravenes the provisions of the Constitution. In Dwarka Prasad v. State
of U.P.,19 the U.P. Coal Control Order 1953 was issued under the Essential Supplies
(Temporary Powers) Act 1946, Even though the parent Act was constitutional, Clause
3(2)(b) of the Order was held ultra vires by the Supreme Court' being violative of
Article 19(1) not (i)(g) of the Constitution of India.
4. Unreasonableness: In England, it is well-settled that the bye-laws made by
corporations boroughs and other local bodies may be declared as ultra vires on the
ground of unreasonableness. In Indian Council of Legal Aid & Advice v. Bar Council

15
Erskire May, Parliamentary Practice, 24th Edition, Lexis Nexis.
16
(1920) 1 KB 829.
17
Sir W. Graham cited by Griffith: Delegated Legislation, Some Recent Developments, (1949) 12 Mod LR 297.
18
AIR 1952 All 795.
19
AIR 1954 SC 224.

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 of India,20 a rule framed by the Bar Council of India barring entry of persons who
have completed 45 years of age from enrolment as advocates was held arbitrary and
unreasonable.
5. Mala-Fide: When a statute enacted by a competent legislature can be challenged as
mala-fide, there is no reason why a delegated legislation is immune from such
challenge.
6. Retrospective Operation: It is well-settled that delegated legislation cannot have any
retrospective effect unless such a power is conferred on the rule-making authority by
the parent Act. The legislature can always legislate prospectively as well as
retrospectively subject to the provisions of the Constitution. But the said rule will not
apply to administrative authorities exercising delegated legis1aive power. Some
statutes specifically confer power to the rule-making authority to frame rules with
retrospective effect. In Stare of M.P. v. Tikamdas,21 the Supreme Court observed:
“There is no doubt that unlike legislation made by a sovereign legislature,
subordinate legislation made by a delegate cannot have retrospective effect unless the
rule-making power in the concerned Statute expressly or by necessary implication
confers powers in this behalf.”

II. Procedural Ultra Vires

When a subordinate legislation fails to comply with certain procedural requirements

prescribed by the Parent Act or by the general law, it is known as procedural ultra vires.

While framing rules, bye-laws, regulations, etc., the parent Act or .enabling statute may
require the delegate to observe a prescribed procedure, such as holding of consultations with
particular bodies or interests, publication of draft rules or bye-laws, laying them before
Parliament, etc. It is incumbent on the delegate to comply with these procedural requirements
and to exercise the power in the manner indicated by the legislature. Failure to comply with
the same may invalidate the rules so framed.22 But at the same time, it is also to be noted that
failure to observe the procedural requirements does not necessarily and always invalidate the
rules. This arises out of a distinction between mandatory requirements and directory
requirements.
20
(1995) 1 SCC 732.
21
(1975) 2 SCC 100.
22
Arvind Kurian Abraham, Delegated Legislation: The Blindspot pf the Parliament, available at:
https://thewire.in/government/delegated-legislation-parliament-executive

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The following are the procedural requirements:

1. Publication
2. Consultation

1. Publication

It is a fundamental principle of law that 'ignorance of law is no excuse' (ignorantia juris non
excusat), but there is also another equally established principle of law that the public must
have access to the law and they should be given an opportunity to know the law. According
to Wade,23 “the very justification for that basic maxim is that the whole of our law, written or
unwritten, is accessible to the public—in the sense, of course, at any rate, its legal advisers
have access to it, at any moment, as of right.”

In the case of an Act made by Parliament, this poses little difficulty as it receives sufficient
publicity during the introduction of a Bill, printing, reference to a Select Committee and its
report thereon, reading before the House or Houses, discussion, voting, final approval of the
Bill, radio and newspaper reports thereon, etc. But this is not true in the case of delegated
legislation.24

M.P. Jain25 rightly stated: “It is essential, therefore, that adequate means are adopted to
publicize delegated legislation so that people are not caught on the wrong foot in ignorance of
the rules applicable to them in a given situation. The system of publication ought to he such
that delegated legislation is not only made known to the people. but it is also easy to locate as
and when necessary.”

In Johnson v. Sargant,26 the impugned order was passed on May 16, but was published on
May 17. The court held that the order could come into operation only on May 17, i.e. when it
was made known.

In India, unlike England and America, there is no statutory provision requiring publication of
delegated legislation. Yet the courts have treated some sort of publication of delegated
legislation as an essential requirement for its validity. In Narendra Kumar V. Union of
India,27 Section 3 of the Essential Commodities Act, 1955 required all the rules to be made

23
Administrative Law, 1994, p. 890.
24
Erskire May, Parliamentary Practice, 24th Edition, Lexis Nexis.
25
Treaties on Administrative Law, 1996, Vol. 1, p. 150.
26
(1918) 1 KB 101.
27
AIR 1960 SC 430.

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under the Act to he notified in the Official Gazette. The principles applied by the licensing
authority for issuing permits for the acquisition of non-ferrous metals were not notified. The
Supreme Court held the rules ineffective.

Once the delegated legislation is promulgated or published, it takes effect from the date of
such promulgation or publication. In Pankaj Jain Agencies v. Union of India,28 the
notification was published in the Government Gazette oil 13, 1986 prescribing the rates of
custom duty which were to come in force from February 19, 1986. The notification was held
valid.

2. Consultation

The term 'consult' implies a conference of two or more persons or an impact of two or more
minds in respect of a topic in order to enable them to evolve a correct or, at least satisfactory
solution of a problem. It is a process which requires meeting of minds between the parties to
consultation on material facts to come to a right conclusion.29

An important measure to check and control the exercise of legislative power by the executive
is the technique of consultation through which affected interests may participate in the rule-
making process. This modus operandi is regarded as a valuable safeguard against misuse of
legislative power by the executive authorities. As Wade and Philips 30 remark: “One way of
avoiding a clash between department exercising legislative powers and the interest most
likely to be affected is to provide for some form of consultation.”

The Administration is not always the repository of ultimate wisdom: it learns from the
suggestions made by outsiders and often benefits from that advice. – M.P. Jain.31

Consultation does not mean consent or concurrence. At the same time, however, it postulates
full and effective deliberation, exchange of mutual viewpoints, meeting of minds and
examination of relative merits of the other point of view. Consultation is not complete unless
the parties thereto make their respective viewpoints known to others and examine relative
merits of their views. Even when consultation is not a legal requirement, such a step
generates greater confidence of the persons who may he affected by an action that may he
taken by the authority.32

28
(1994) 5 SCC 198.
29
Union of India v. S.H. Sheth (1977) 4 SCC 193.
30
Constitutional Law, 1960, p. 184.
31
M.P. Jain, Treaties on Administrative Law, (1996), Vol. 1.
32
Prakash Chand v. Zila Parishad (1971) 2 SCC 489.

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In England, though there is no statutory provision requiring consultation of affected interests
before the making of subordinate legislation, it is considered mandatory. This practice is so
well-established that “no Minister in his senses, with the fear of Parliament before his eyes
would ever think of making regulations without (where practicable) giving the persons who
will be affected thereby or their representatives an opportunity of saying what they think
about the proposal.”33

India there is no general statutory provision requiring consultation with the affected interests
in the making of delegated legislation. But some statutes specifically provide for consultation
which fall under the following heads:

 Official Consultation.
 Consultation with statutory bodies.
 Consultation with advisory bodies.
 Draft rules by affected interests.

In Ibrahim v. Regional Transport Authority,34 consultation with the Municipality was

required to be made by the Transport Authority before certain routes for public buses were
fixed. The Supreme Court held it to be merely directory.

Similarly, in Hindustan Zinc lid. v. Andhra Pradesh State Electricity Board, 35 the Apex Court
held that failure on the part of the Board to consult the Electricity Council before revising
electricity tariffs was not bad. One of the factors considered by the Court was that the
consequence of non-compliance was not provided by the Act and, hence, at the most such
consultation could be said to be persuasive.

CONCLUSION

Pre-constitutional control to post-constitutional judicial control found a big shift from the
scrutiny of delegated legislation confined to the area of sub-delegation from British

33
Sir W. Graham cited by Griffith: Delegated Legislation, Some Recent Developments, (1949) 12 Mod LR 297.
34
AIR 1953 SC 79.
35
(1991) 3 SCC 299.

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Parliament to Indian legislature36 and laying down a fundamental principle of delegation in
the post-constitutional era37 which can be stated as follows:-

“Legislatures cannot delegate their essential legislative powers. Essential legislative powers
relate to the determination of the policy of the legislature and of rendering that policy into a
binding rule of conduct”.38

In the fitness of things, it would be proper to suggest that the rules laid down by the Judiciary
may be codified, so as to confine its powers to the norms already laid down. It is also
necessary that the Supreme Court must frame rules under Art 141, which would be law
binding under Art 144 limiting its powers judiciously and not to overstep its legitimate
sphere. In other words, self –imposed rules by the supreme court may be a good solution to
the problems of Judicial control being made accountable, legitimate and confined to
constitutional limits to protect and preserve the Constitution and ‘rule of law’.

It would be worthwhile to remember the famous observation of Justice Frankfurter 39 which is

in these words: “Judicial review is not immune against human weakness. It also must be on
guard against encroaching beyond its bounds, and not the less so, since only restraint upon it
is self-restraint”. It is hoped that the apex court will frame rules relating to its power of
review in the sphere of delegated legislation, so that it could serve as guidelines to all High
Courts and also to the Govt., to keep in mind while framing rules as well to the legislatures,
while enacting laws. It will go a long way in preserving the constitutional powers and the rule
of law in a democratic society like ours.

BIBLIOGRAPHY

Books

36
Empress v. Burah (1877) 3 Cal.
37
In re Delhi Law Act case AIR 1951 SC.
38
Ibid.
39
Trop v. Dulles 356 US 86 (158).

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  Jain, M.P. & Jain, S.N.; Principles of Administrative Law, 6th Ed., Vol. II, Wadhwa
Nagpur, 2007.

 Kumar, Narender; Nature and Concepts of Administrative Law, 1st Ed., Allahabad
Law Agency, Faridabad, 2011.

 Upadhyaya, Dr. J.J.R.; Administrative Law, 7th Ed., Central Law Agency, Allahabad,
2011.

 Takwani, C.K.: Lectures on Administrative Law, 4th Edition, Eastern Book Company,
2011.

 M.P. Jain, Treaties on Administrative Law, Vol. 1, 1996.

 Erskire May, Parliamentary Practice, 24th Edition, Lexis Nexis.

Journals & Articles

 Sir W. Graham cited by Griffith: Delegated Legislation, Some Recent Developments,

(1949) 12 Mod LR 297.
 Legal Services India, Delegated Legislation Development and Parliamentary Control
in India, available at: https://www.legalservicesindia.com/article/2421/Delegated-
Legislation-Development-and-Parliamentary-Control.html
 Arvind Kurian Abraham, Delegated Legislation: The Blindspot pf the Parliament,
available at: https://thewire.in/government/delegated-legislation-parliament-executive
 PRS Legislative Research, Parliamentary Scrutiny of Executive Rule Making,
available at:
https://prsindia.org/files/parliament/discussion_papers/1370586704_Parliamentary
%20Scrutiny%20of%20Executive%20Rule%20Making.pdf
 Prof. Dr. Mukund Sharda, Judicial Control Over Delegated Legislation, IJLR 2017.

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