S.R.S. Travels vs Karnataka State Road Transport Corporation Workers 2025 INSC 152 - Motor Vehicles Act - Repeal Of KCCA Act - Delegation - Legislation - Repeal
Karnataka Motor Vehicles Taxation and Certain Other Law (Amendment) Act, 2003- Section 3- Section 3 which repeals the KCCA Act, is constitutional - The rationale underlying the 2003 Repeal Act is sound and consistent with the principles of legislative power. The arguments advanced that the repeal would amount to an impermissible overruling of prior Supreme Court decisions, that it violates the requirement of presidential assent, or that it is otherwise beyond the legislative competence of the State, are untenable. (Para 17)
Motor Vehicles Act - Section 68(5) ; KMV Rules, 198 - Rule 56(1)(d)- The State Transport Authority (STA) possesses the power to delegate its functions under Section 68(5) of the MV Act, as expressly provided by the statute and further clarified by Rule 56(1)(d) of the KMV Rules- The delegation is a rational and necessary administrative measure that facilitates prompt and efficient processing of permit applications without undermining the oversight function of the STA. (Para 27-28)
Legislation - The power to repeal a law is coextensive with the power to enact it. (Para 10) A repeal statute does not recreate the legal framework anew but rather extinguishes the earlier Act’s operative provisions; it is not subject to the same procedural requirements as an original enactment when it comes to the need for fresh assent, provided that the repeal falls within the legislative competence of the State. (Para 13)
Legislation - Legislature may, subject to constitutional limitations, repeal any law it has enacted -If the Legislature has the power to enact a law on a particular subject, it equally possesses the power to repeal that law. (Para 15) - Merely because Supreme Court decisions affirmed the constitutional validity of a Statute at the time of its enactment; they do not bind the Legislature from modifying or repealing a statute when subsequent developments warrant a change in policy. (Para 13)
Administrative law - Quasi-judicial functions may be delegated if the enabling statute expressly provides for such delegation. (Para 23)
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