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Sunday, August 16, 2015

The Question of Retrospectivity or Retrospective Operation of Circulars


Often this question arises as to whether Circulars can be made operational with retrospective effect. The law laid down by the Apex Court in respect to this question is not inside a straightjacket. A Circular issued by State Government or Central Government is a form of Delegated Legislation. Various other expressions and words are also used to denote similar and identical forms of Delegated Legislation such as Order, Directions, Schemes, Notification, bye-laws and Instructions etc. As mentioned above, there is no straight answer to this question. However, following points are to be kept in mind before answering it:

1. A beneficial circular has to be applied retrospectively while an oppressive circular has to be applied prospectively. Thus, when the circular is against the respondents, they have a right to claim the enforcement of the same prospectively. This was laid down in CCE v. Mysore Electricals Industries Ltd.[1].

2. In ITO v. M.C. Ponnoose[2], it was stated that:

“The courts will not, therefore, ascribe retrospectively to new laws affecting rights unless by express words or necessary implication it appears that such was the intention of the Legislature. Parliament can delegate its legislative power within the recognised limits. Where any rule or regulation is made by any person or authority to whom such powers have been delegated by the Legislature it may or may not be possible to make the same so as to give retrospective operation. It will depend on the language employed in the statutory provision which may in express terms or by necessary implication empower the authority concerned to make a rule or regulation with retrospective effect. But where no such language is to be found it has been held by the courts that the persons or authority exercising subordinate legislative functions cannot make a rule, regulation or bye-law which can operate with retrospective effect.”

3. In the same case, another Supreme Court Judgment, B.S. Vadera etc. v. Union of India & Others[3], was distinguished by the court in the following language:

“It may be noticed that in a recent decision of the Constitution Bench of this Court in B.S. Vadera etc. v. Union of India [AIR 1969 SC 118] it has been observed with reference to rules framed under the proviso to Article 309 of the Constitution that these rules can be made with retrospective operation. This view was, however, expressed owing to the language employed in the proviso to Article 309 that ‘any rules so made shall have effect subject to the provisions of any such Act’. As has been pointed out the clear and unambiguous expressions used in the Constitution, must be given their full and unrestricted meaning unless hedged in by any limitations. Moreover when the language employed in the main part of Article 309 is compared with that of the proviso it becomes clear that the power given to the Legislature for laying down the conditions is identical with the power given to the President or the Governor, as the case may be, in the matter of regulating the recruitment of government servants and their conditions of service. The Legislature, however, can regulate the recruitment and conditions of service for all times whereas the President and the Governor can do so only till a provision in that behalf is made by or under an Act of the appropriate Legislature. As the Legislature can legislate prospectively as well as retrospectively there can be hardly any justification for saying that the President or the Governor should not be able to make rules in the same manner so as to give them prospective as well as retrospective operation. For these reasons the ambit and content of the rule-making power under Article 309 can furnish no analogy or parallel to the present case. The High Court was consequently right in coming to the conclusion that the action taken by the Tahsildar in attaching the shares was unsustainable.”

4. It has been said in a plethora of cases, both by the Supreme Court and the various High Courts that an enactment would not be construed as retrospective unless the same were to have that effect by express language or by necessary implication. The phrase “necessary implication” has also been elucidated by the Supreme Court in Indramani Pyarelal Gupta v. W.R. Natu[4], as follows:

“The phrase “necessary implication”, as applied in the law of statutory construction, means an implication that is absolutely necessary and unavoidable that is to say, a court must come to the conclusion that unless such an implication is made, the provisions of the section could not be given full effect on the wording as expressed therein.”

Thus we will have to see whether the Circular in question has been enacted under some parent act or law by the Government or has it been independently enacted by the Government. It is usually not the case that Government can enact a Circular out of the blue and without any backing of a legislation. The power to enact rules or circulars or bye-laws is usually derived from some parent law.

Only in cases like that of Proviso to Article 309, can the Government enact a law with retrospective operation and even in those cases, the rights of the parties would be of significance in deciding the validity of retrospective operation.

The Supreme Court has also said that a beneficial circular has to be applied retrospectively while an oppressive circular has to be applied prospectively. This clearly means that if a Circular is adversely affecting the rights of the persons on whom it is applied, then it cannot be applied in retrospectivity.

The judgments of the Supreme Court mentioned above have been cited by a number of High Courts such Allahabad High Court, Karnataka High Court, Gujarat High Court etc.



[1] (2006) 12 SCC 448 at page 451.
[2] (1969) 2 SCC 351 at page 354.
[3] AIR 1969 SC 118.
[4] , (1963) 1 SCR 721 : AIR 1963 SC 274.

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