1 Administrative Law

School of Law, Hyderabad.

Project Topic: Delegated legislations - Meaning, reasons for growth,

permissible limits

Submitted to: Prof. Sridip Nambiar

Submitted by: Gayathri Praharshitha K

SAP ID: 81021319023

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Contents
Introduction..............................................................................................2
Meaning.....................................................................................................3
History of delegated legislation...............................................................4
Significance and need for delegated legislation.....................................5
Delegated legislation & the Constitution of India.................................6
Reasons for growth...................................................................................8
1. Pressure on the Parliamentary time:.................................................8
2. Technicality in matters......................................................................8
3. Flexibility..........................................................................................9
4. Emergency........................................................................................9
5. Experiment........................................................................................9
6. Modern administration's complexity...............................................10
Types of Delegated legislation...............................................................10
1. Orders in Councils:.........................................................................10
2. The rules of the Supreme Court and the County Courts:................11
3. Instructions or rules issued by the Department or the Executive:. .11
4. Delegated legislation by laws:........................................................11
i. Autonomous bodies' by-laws:...................................................11
ii. Local authority bylaws:.............................................................12
Permissible limits (functions which can be delegated)........................12
Commencement:....................................................................................12
The Power of Inclusion and exclusion:.................................................12
Power to exempt....................................................................................14
Power to modify....................................................................................15
Removal of Difficulties.........................................................................16
Conclusion...............................................................................................17
References...............................................................................................18

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Introduction
The Indian Constitution vests in the legislature the power to make national legislation. One
of the most essential legislative duties is determining a legislative policy and defining it as a
rule of behaviour. Other institutions, obviously, cannot be granted such authority. However,
given the large variety of responsibilities carried out by a welfare state, the legislature will be
unable to do all of them. Delegated legislation comes into effect in certain situations.

Delegated legislation, which compels the executive to carry out some legislative tasks, is one
of the most significant components of administration. It's crucial, though, not to
underestimate the risk that comes with delegating. Overworked legislators are prone to
going over delegation limits needlessly. It may not adopt any policy; it may declare any of its
policies to be ambiguous; and it may provide any guidelines for the executive, allowing the
executive to amend or modify any policy it has established without relinquishing power over
subordinate laws. As a consequence, although the Legislature may delegate some of its
responsibilities, it must retain total control over those duties.

Delegated legislation (also known as secondary legislation, subordinate legislation, or

subsidiary legislation) is a process in which main legislation empowers the executive branch
to create laws to carry out and administer the provisions of the original legislation. Such
legislation is passed by someone or something other than the legislature, yet with the
legislature's power.

Legislation passed by any statutory authority, municipal or other institution other than the
Legislature but within the jurisdiction of the relevant legislature is known as delegated
legislation. Someone or something other than Parliament enacts legislation. Through
primary legislation, Parliament grants others the authority to establish laws and regulations
through a delegated legislative method.

Meaning

"As an act of entrusting a person with the authority or authorising him to act on behalf of
that person who has given him that power or to serve as his agent or representative,"
according to Black's Law Dictionary.

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The term "delegated legislation" refers to the exercise of legislative authority by a lower-
ranking or subordinate agency to the Legislature. Auxiliary legislation, also known as
delegated legislation, is legislation passed by someone or something other than Parliament.
Through an Act of Parliament, Parliament may delegate power to a person or an
organisation to enact laws. An Act of Parliament creates a specialised or narrow legal system
and generally provides a statement of the Act's purpose. Different persons or organisations
are authorised to add further details to an Act of Parliament by delegating it to the Executive
or another subordinate.

Delegated legislation, according to Sir John Salmond, "comes from any authority other than
the sovereign power."

"Delegated legislation is a phrase that encompassed a plethora of confusion," Justice P.B

Mukherjee said. He saw it as a shelter for Executors, an excuse for the Legislature, and a
provocation to the Constitutional Jurist."

According to M.P. Jain, this phrase may be interpreted in two ways:

"Exercise by a subordinate agency or a lower-ranking agency of powers given to it by the

Legislature."

"The Subordinate Authority's subsidiary regulations enacted in the exercise of the

jurisdiction conferred to it by the Legislature."

Delegated legislation is referred to as subordinate, auxiliary, administrative, or quasi-

legislation.

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Delegated legislation's history

The history of power delegation may be traced back to the East India Company's regaining
political strength in India with the Charter Act of 1833. Under the Charter Act of 1833, only
the Governor-General-in-Council, who was an official body, had administrative powers. He
had the power to make laws and rules that could be used to repeal, correct, or change any
laws or guidelines that applied to everyone, regardless of country. In 1935, the Government
of India Act was established, which featured a serious delegation plan. The Committee of
Ministerial Powers' report was given and endorsed, bringing to a close the argument for the
assignment of troops and the appointment of leaders, which had been deemed inevitable in
India.

Because a perfect division of forces was impossible to achieve, our Constitution was based
on the separation of powers; as a result, it preserved the tenet's holiness in a cutting-edge
sense. The Indian Constitution does not ban the deployment of military. However, the
official has been given authorization to cooperate with the administrative forces in a few
circumstances. The Indian Constitution, for example, places a strong emphasis on the
President's administrative forces. The subject of legislative delegation in India arose under
British rule, at a time when the argument in the West was at its most heated. The effort to
solve the issue of parliamentary delegation in independent India looked to be a contest
between English and American approaches.

In the matter of Queen v. Burah, the Privy Council considered the nature and scope of
legislative authority, as well as the feasibility of delegation. The Privy Council determined
that the Governor-Council General is the highest legislative in this case, with a broad variety
of powers, including the ability to delegate some responsibilities to provincial executors.
When the New Delhi Act of 1912 was approved, the Privy Council consented to the
devolution of legislative authority to the Executive.

The importance of delegated legislation and the necessity for it

Delegated legislation enables the government to enact laws without having to wait for a
new Act of Parliament. Delegated legislation also grants the ability to alter or amend a
statute's punishments, as well as make technical modifications to the law. Because there is

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more delegated legislation than Acts of Parliament each year, it is very important in the law-
making process. Delegated legislation also has the same legal standing as the Act of
Parliament that established it.

For a variety of reasons, delegated law is crucial. They are as follows:

By enabling the administration to enact or alter laws within the authority of the legislature,
Delegated Legislation relieves the already overworked Legislature of some of its tasks. As a
consequence, the Legislature may concentrate on more important concerns and develop
measures to solve them.

It gives individuals with the required knowledge and skill the authority to enact laws. For
example, rather than creating rules that may or may not apply to their region, a local
government might be permitted to enact legislation tailored to their area, taking into
consideration local requirements.

In an emergency, delegated legislation is also useful since it avoids the need to wait for a
special Act to be approved by Parliament to resolve the problem.

Delegated legislation usually addresses issues that Parliament did not foresee at the time of
adoption, making it adaptable and useful in the legislative process. As a consequence,
delegated law may adapt to changing social needs as well as circumstances that Parliament
could not foresee when the Act of Parliament was enacted.

The Indian Constitution and delegated legislation

Despite the fact that the Indian Constitution does not specifically address the subject of
delegated legislation, it may be understood by studying Article 312. The Rajya Sabha has the
ability to establish a new branch of the All-India Service with a two-thirds majority vote. This

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suggests that the new All-India Service recruitment would be granted legislative jurisdiction.
Various instances of delegated legislation under the Indian constitution may be explored.

The State of Punjab v. D.S. Grewal

Facts:

This case claims that the All-India Service Act of 1951 is unconstitutional. The All-India
Service assigned the appellant to the Punjab State. He was reverted or restored to the post
of Assistant Superintendent of Police in August 1957, and he was sent to Dharamsala in
March the following year.

In the same month, he received notice that he was under investigation under Rule 5 of the
All-India Services (Discipline and Appeal) Rules, 1955. An investigative committee was
created against him under the direction of Shri K. L. Bhudiraja. He then filed an appeal with
the Punjab High Court under Article 226 of the Indian Constitution, contesting the legitimacy
of the Act as well as the legality of the inquiry against him. Six arguments were offered by
the appellant's counsel.

Judgment:

The Indian Supreme Court's Justice K.N. Wanchu was disputing the authority of delegated
legislation under Article 312 of the Indian Constitution at the time. The appellant may be
dismissed or compelled to retire from his job by the Central Government since the situation
is so severe, which is why an inquiry has been opened against him. Article 312 of the Indian
Constitution has no limitations on delegation power.

The Congress in India and America has limited delegation authority, in contrast to the
English parliament, which is paramount and has extensive delegation authority.

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Rayan v. Panama Refining Co.

Facts:

Under Section 9(c) of the National Industrial Recovery Act of 1933, the President of the
United States has several rights, including the authority to make any order, and any violation
of such an order may result in a panel provision. The President utilised the executive branch
to implement the above-mentioned restriction, and under section 9(c) of the Act, the
Secretary of the Interior was granted authority to exercise all of the President's powers. The
Secretary of the Interior issued a rule in response to the President's directive (s). Congress'
devolution of legislative authority was contested in the above-mentioned provision.

Judgment:

The United States Supreme Court determined that the President's delegation of legislative
authority is null and invalid. Congress may only transfer authority to the President under two
circumstances, according to the Supreme Court. To begin, these rules were created by the
Statute. Second, standards must be established, and the administration must be given the
right to adopt subordinate regulations within certain limitations.

Surendra Sharma v. Sikkim

Facts:

When Sikkim became a state of the Union of India, the Directorate of Survey and Settlement
of the Government of Sikkim established and advertised for temporary jobs. The responder,

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like everyone else, applied for the position. They were allocated to different jobs after being
selected for them. Following the completion of the survey work, several staff were fired. In
1982, several of the 'non-local' workers filed a writ action in the High Court of Sikkim,
contesting the Government's decision and asking why they were sacked since they were not
locals.

Judgment:

According to Articles 14 and 16 of the Indian Constitution, firing an employee only because
he is not a resident of India is prohibited. All rules and statutes adopted within the authority
granted by Article 371F, subclause (k), were considered subordinate legislation. This article
was added to the Constitution by the 36th Constitutional Amendment.

Reasons for expansion

Time constraints in Parliament:

Every day, the territory, scope, or horizon of state action expands, making it harder for
Parliament to pass laws on every issue since they have a lot of work to do and must draught
legislation on a number of topics. The Parliament is so consumed with foreign policy and
political matters that it doesn't have much time to pass comprehensive legislation. As a
consequence, it just lays out the broad strokes of the rule and the law's idea, leaving it up to
the executive or some of its subordinates to fill in the specifics while complying to the
applicable rules and regulations.

According to the Committee on Ministerial Power, if the parliament refuses to provide the
subordinate law-making power, he will be unable to enact the high-quality rules and
regulations that a pleasant living demands, as well as the laws that a contemporary public
requires.

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In terms of technicality,

As civilization has grown, things have gotten more twisted, complicated, and technological.
As a result, lawmakers want the experience of a subject specialist who is well-versed in every
aspect of the subject in order to comprehend the complexities of each issue. It has been
observed throughout time that some lawmakers are just informed about politics, while
others are knowledgeable about one or two topics. As a consequence, when the parliament
has formulated policies on a particular issue, that topic is handed to a government agency or
any person competent about the mechanics of that field and given the ability to lay down
the specifics.

Flexibility

Parliamentary amendment takes a long time to produce any sort of law, but with the
instrument of delegated legislation, such as police regulation, bank rates, import and export,
foreign currency, and so on, it can be done swiftly with the aid of the executives.
Furthermore, since Parliament cannot foresee every situation while adopting legislation, the
executive bears the brunt of the responsibility. As a consequence, it is critical to provide
lower-body labour in order for that task to go smoothly and effectively.

Emergency

Anyone should be prepared to react quickly and efficiently in any kind of emergency. The
legislature lacks the essential ability to respond quickly to an emergency situation. Delegated
legislation is the only way to deal with this situation. As a consequence, the executive branch
is given considerable power to deal with the situation in times of emergency or war. During
the First and Second World Wars, examples include the Defence of the Realm Act 1914-15,
the Emergency Power Act 1920, and various acts of delegation in England. Similarly, rapid
action is necessary in the case of inflation, a flood, an epidemic, an economic slump, or other
comparable disasters.

Experiment

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Delegated legislation permits the Executive to experiment with new ideas. Because every
assignment is new to the lawmaker, he must determine whether or not the legislation is
effective. This technique or approach allows for the application of past experience and the
acceptance of critical improvements to the Parliament's laws. For example, in road traffic
problems, an experiment approach may be employed, and as a consequence of its
execution, essential adjustments to the regulations can be made. The advantages of such a
path are that it enables the delegated authority to consult with people on the ground to
establish what kind of legislation affects them, and then experiment by amending the laws.

The difficulty of modern administration

When it came to enhancing the living circumstances of people, contemporary administration

took on new responsibilities such as job security, health care, education, trade control, and
so on. A new form of legislation has evolved as a consequence of the complexity of
contemporary administration and the extension of governments' tasks into the social and
economic realms, providing vast powers to several agencies at different periods. In order to
activate socioeconomic programmes, it is vital that a government award itself too much
authority. In a nation like Bangladesh, where the government may need to manage private
trade, companies, or property, the administration must delegate an excessive amount of
authority to carry out such programmes.

Delegated Legislation Types

Orders Issued by Councils:

This kind of delegated legislation may be issued by Queens or Privy Councils. Delegated
legislation enables Parliament to approve legislation without going through the traditional
legislative procedure. Its principal job currently is to give European directives legal effect.
When a court grants an order under the Queen's or Crown's privilege, it is subject to judicial
review. The order, however, may or may not be subject to judicial review since it is issued
within the authorised limitations of the Act of Parliament.

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The issue of whether this law is equivalent to Executive legislation may arise in both
circumstances. Yes, it is the same as executive legislative power. Between these directives
and executive legislation, there isn't much of a difference; they're almost similar. A meeting
of Privy Councillors might simply refer to a gathering of three or four ministers, the President
of Councils, and the Clerk of Privy Councils in this case. This indicates that the Executive,
acting under Council authority, issued this instruction.

The Supreme Court and County Court Rules are as follows:

Through statutes, the Parliament gives specified persons or authorities the ability to make
laws for a specific purpose. However, in England, a Court has been granted significant
legislative powers. The Rules Committee of the Supreme Court and the County Courts have
been charged with the task of formulating law. Entrusting a major share of the authority
over procedural law to the judicial branch has the benefit of placing it in the hands of
someone who knows more about it than anybody else. The Rules Committee of the County
Courts writes up the process and expenses, which are dealt with by the County Courts. Such
regulations are not subject to scrutiny by the legislature. When the Lord Chancellors ratify
the regulations with the Supreme Court's Rules Committee's approval, they become
effective.

The Department or the Executive has issued the following instructions or rules:

Departmental or Executional Instructions or Regulations are used when the legislative has
specifically assigned a power to the administration, such as a Board, Ministers, or a
committee. Extremely extensive powers are occasionally delegated to the administration or
the authorised person. On the other side, the court opposes this extensive delegation of
legislative power since it makes it more difficult for them to supervise administrative
conduct. This delegated legislation is extensively employed in today's globe. Only the broad
line of creating laws is now in Parliament's hands, with the Administrator retaining the rest
of the authority.

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Legislation delegated by laws:

It may be supplied in two ways: first, via laws established by autonomous entities such as
businesses, and second, through by-laws issued by municipal governments.

Bylaws of autonomous bodies:

These bodies have the power to establish bylaws that effect them as well as other people in
the neighbourhood or who reside in a certain region. They may, for example, make
legislation for light, water, and other services as a public utility authority. These authorities
are usually granted the power to set rules to control their activities. Such bylaws may be
subject to judicial scrutiny. It may be investigated to discover whether it violates the Parent
Statute. These self-governing entities have the power to establish their own rules. Another
example of an independent entity is an employer's association. These organisations' policies
are described as "voluntary," yet this is not the reality. It's a fallacy since these rules bind
members in the same way that other regulations, such as those of a professional group or a
trade union, do.

Bylaws of local governments:

The ability to form new local bodies or change existing ones belongs to Parliament. It
empowers such a body to make bylaws for certain purposes. In the guise of public health,
safety, and good government, these agencies abuse their authority. If these ordinances are
breached, there is a punishment.

Limits that are acceptable (functions which can be delegated)

Commencement:

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Appointment day clauses are included in many legislation, allowing the government to
specify a day for the act to take effect. The government's decision affects the legislation's
implementation. For example, section 3 of the Bombay rentals, hotel and lodging house
rates control act 1947 stipulates that the act would take effect on the date determined by
the state government by notice in the official gazette. A provision like this is legal.

Inclusion and Exclusion's Power:

Individuals, entities, or commodities may be subjected to or exempted from the jurisdiction

of a legislation if the government is granted the ability to do so.

The Act applies to the things mentioned in the attached schedule, although the government
has the ability to amend the schedule by adding or removing items from it, according to a
standard legislative formula. As a consequence, the Act's scope of operation may be
enlarged or reduced by altering the schedule via delegated legislation. This is an example of
a lawful provision that has been preserved.

The Minimum Salaries Act of 1948, for example, was created "to permit the establishment of
minimum pay in specified professions." The Act only applies to the employment on the
schedule, but the government has the power to add any new job to the schedule and
therefore extend the Act to that job.

In Edward Mills Co. v. State of Ajmer, the Supreme Court upheld the provision, stating that
the purpose of the Act was to control minimum wages in order to prevent exploitation of
workers in businesses where wages were low owing to unorganised labour or other
circumstances.

In a number of instances, the ability to change the schedule has been affirmed because the
Act's objective of giving advice to the government was obvious. It is constitutional for the
legislature to delegate to the executive topics connected to the operation of taxation laws,

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such as the selection of individuals to whom tax will be applied, the rates at which tax will be
imposed, in relation to different categories of goods, and so on. The ability placed on the
State Government by s. 6(2) of the C.P. and Berar Sales Tax Act, 1947 to amend the schedule
related to exemption is in conformity with recognised legislative practise on the topic and is
not unconstitutional, according to Banarsidas Bhanot v. State of Madhya Pradesh.

Except for those stated in the annexed schedule, the Punjab General Sales Tax Act of 1948
levied a purchase tax on all items. The State Government might add to or delete any item
from the programme with three months' notice. This meant that if the government added
anything to the schedule, it was tax-free; if the government removed something from the
schedule, it was charged. The Supreme Court determined that it was taxed since it was not
on the timetable.

The provision was affirmed by the Supreme Court against objections based on undue
delegation on two grounds.

The right to adjust timetables is often entrusted to the Executive, and this power has been
maintained in a number of instances.

Changes to the schedule might be made with three months' notice. This served as a check on
the use of power in arbitrary ways. The government would provide advance notice of its
intention to change the schedule, as well as a chance for interested parties to protest to the
proposed changes. In a democratic government, this mechanism serves as a check on the
exercise of arbitrary authority. The delegation of legislative authority was sustained in this
instance because it was subject to the procedural safeguard of three months notice.

Exemption authority

The legislature may exclude any person, institution, or product from its authority.

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An exception clause serves the following purposes:

minimise the legislature's workload; and

easing the suffering of individuals who may be impacted by the act's policies

An example of a typical provision is as follows:

"Notwithstanding anything in this Act, the Government may, subject to such conditions as
they deem fit, exempt any land or building or class of land or buildings from all or any of the
provisions of this Act or rules and regulations made there under, by notification." [Section
113 of the Tamil Nadu Town and Country Planning Act, 1971]

The clause may be ruled unconstitutional if the Act lacks any policy, rules, or principles to
guide the government's power to exempt under this paragraph.

The exemption clause in A.N. Parsuraman v. State of Tamil Nadu was defined as
"uncanalized, unfettered, and arbitrary" since the Act did not create any foundation or
principle to guide the government's ability to exclude.

In Jalan Trading Co. v. Mill Mazdoor Union, the Supreme Court upheld section 36 of the
Payment of Bonus Act, 1965, which allows the government to exempt any establishment
from the Act's application based on its financial situation and other relevant circumstances,
because Parliament had provided adequate guidance and laid out the principles on which
the exemption power is to be exercised.

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It was established in I.T.C. Bhadrachalam Paperboards v. Mandal Revenue Officer that the
executive's capacity to put an Act into effect, as well as the power to exclude individuals or
assets from the enactment's operation, are examples of conditional legislation.

The ability to change

A law may provide the executive the ability to alter or amend the parent legislation. Despite
the fact that this authority gives the executive primacy over the legislative, it also provides
for flexibility in times of change. As an example,

When a complicated approach is implemented in order to cope with any unanticipated

challenges.

To prevent the legislature from failing to make the necessary changes to the statute.

In Baburam Jagdish Kumar & Co. v. State of Punjab, the court held that the legislature's
delegation of power to a local authority or executive government to vary or modify an
existing law was not unconstitutional as long as the delegation did not result in the
legislature abdicating essential legislative power, i.e., necessary guidelines were provided.

According to the Patna Administration Committee, the relevant statutory provision in

Rajnarain v. Chairman allowed the State Government to extend any section of the legislation
(The Bihar and Orissa Municipal Act, 1922) to a specific area, subject to "such restrictions
and adjustments as the Government may see appropriate." The Supreme Court upheld the
delegation of authority, but only if the government could not modify the Act's essential
policy, as it did in the Delhi case. "When a component of an Act is chosen for application,
whether altered or not," the Court stated, "it must be done in such a way as not to influence
any change of policy, or any significant change in the Act as a whole."

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The government was granted the ability to amend the timetable with three months' notice
in Lachmi Narain V. Union of India & Ors. In addition, the government was granted the
power to make whatever adjustments it "sees appropriate." The administration tried to
amend the Act by removing the three-month notice requirement for schedule changes. The
Supreme Court ruled that this alteration constituted ultra-vires since it changed the Act's
"essential ingredient" and "legislative policy." The Court held that the three-month notice
requirement for modifying the schedule was a policy requirement because it was necessary
to provide enough notice to those who would be affected so that they may properly object
to the proposed change.

Difficulties are removed

Because "that king is often seen as the epitome of executive authoritarianism," the Henry
VIII clause is known in Britain as the "removal of problems clause."

The clause is commonly used when the Legislature adopts a measure that establishes a new
socioeconomic framework. Because the Legislature is unknown what obstacles may develop
in the future execution of the legislation's provisions, it contains a "removal of difficulty"
clause that empowers the government to adopt measures to handle any challenges that may
arise.

There are two sorts of "difficulty removal" clauses:

(a) A restricted power in which the "power to remove barriers" must be used in conformity
with the parent Act's limitations. The government is unable to amend any of the statute's
provisions in this case.

In this scenario, the Executive Order issued to fix the problem should not change the
fundamental policy of the parent Act. The order to eliminate obstacles is solely meant to
give effect to the parent Act, not to change any of its provisions.

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(a) The second, more expansive version might allow revisions to the parent Act or any other
Act in the name of removing impediments. Typically, such authority is limited in duration,
such as two or three years. In essence, such power is problematic since it vests the Executive
with a vast array of authorities.

For the Executive to issue a removal of difficulty order, three requirements must be met:

(1) A problem has emerged in putting the scheme's provisions into effect.

(2) that the government thinks the order to be necessary or expedient in addressing the
situation; and

(3) that the order does not contradict with any of the scheme's provisions.

The following are some key elements to remember regarding the Henry VIII clause:

There are no amendments to the parent Act authorised here, and the lifting of the difficulty
order is not definitive; its legality may be disputed in court.

The ability to solve an issue can't be employed if there isn't one. As a consequence, the court
can determine whether or not there is an issue.

Only minor modifications to the parent Act are authorised; the core aspects of the Act
cannot be modified.

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In Jalan trading firm v. Mill Majdoor union, the Supreme Court was urged to decide on the
constitutionality of section 37 of the Payment of Bonus Act, 1965. By a 3:2 majority, the
court found that section 37 of the stated legislation is supra vires because of excessive
delegation. The court went on to conclude that the executive branch had been wrongly
given such powers by the federal government.

Later, in Gammon India ltd v. Union of India, the court followed the Jalan trade case's
minority decision, concluding that delegation was legal since the central government's
powers were not legislative.

Following that, in Patna University v. Amita Tiwari, the court determined that the "removal
of difficulty" clause had a restricted reach and could not be employed in every situation
involving some difficulty.

Conclusion

Delegation of authority is advantageous, but too much delegation is detrimental. Delegation

has many benefits, including lessening the legislature's burden, but what the legislature
must do must be done by itself. As a result, the unacceptable boundaries of delegated
legislation are a clearly defined region beyond which no delegation of authority is
permissible. Delegation of powers may also help divide a large task, but safeguards and
appropriate control mechanisms must be created and implemented to guarantee that
delegation of powers is properly canalised and regulated.

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References

Lectures on Administrative Law, 4th edition, C.K. Takwani, 2008.

Principles of Administrative Law, 6th edition, M.P. Jain and S.N. Jain, 2010.

Administrative Law, 3rd Edition, Paras Diwan, 2004.

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Lectures on Administrative Law by Takwani and Thakkar

https://www.jstor.org/stable/43951254?readnow=1&seq=3#metadata info tab contents

[1878] UKPC 26 Queen v. Burah

D.S. Grewal v. Punjab State, 1959 AIR 512

Ryan v. Panama Refining Co., 293 U.S. 388

Surendra Prasad Sharma vs. State of Sikkim, 1994 AIR 2342

https://rajyasabha.nic.in/rsnew/practice procedure/book13.asp

143 U.S. 649, Field v. Clarke (1892)

Southard v. Wagman, 23 U.S. 10 Wheat. 1 (1825)

Chairman, Patna Administration Committee v. Raj Narain Singh, 1954 AIR 569

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Air 1976 Sc 714, Lachmi Narain v. Union of India

[1898] 2 QB 91 Kruse v. Johnson

AIR 332 In Re The Delhi Laws Act, 1951

Chintaman Rao and Others v. Madhya Pradesh State, 1951 AIR 118

1.

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