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Judgment
Subrahmanyam, J.—The question that arises on these references made by the learned District Munsif of Turaiyur is whether Madras Act
XIV of 1956 is an effective piece of legislation. The title given to the Act by the Madras Legislature is:
An act to amend and extend the duration of the Madras Cultivating Tenants Protection Act, 1955.
The Madras Cultivating Tenants Protection Act, 1955 (Madras Act XXV of 1955, hereinafter referred to as Act XXV) protected a cultivating
tenant from eviction from the holding in his occupation or any part thereof, during the continuance of the Act, by or at the instance of his landlord,
whether in execution of a decree or order of a Court or otherwise. The protection, however, would not be available to a cultivating tenant who
was not regular in the payment of the rent due, or who used the land for any purpose not being an agricultural or horticultural purpose, or did any
of the other acts described in greater detail in Section 3(2) of the Act, which rendered the cultivating tenant ineligible to be continued in occupation
of the land. If a cultivating tenant had rendered himself liable to be evicted for failure to pay rent, or by reason of the commission of the acts
described in Section 3(2), and the landlord wished to evict such cultivating tenant, the landlord had to apply to the Revenue Divisional Officer
having jurisdiction over the area in which the land was situate for eviction of the cultivating tenant. In relation to cultivating tenants, the jurisdiction of
civil Court to pass any decree or order for eviction was expressly barred by Section 6 of Act XXV.
Section 1(3) of Act XXV said that the Act ''shall remain in force for a period of one year ''. The Act came into force on the 27th September
1955, and expired with the 26th September 1956.
Madras Act XIV of 1956 (hereinafter referred to as Act XIV) was placed on the statute book on 1st October 1956. In Act XIV, Act XXV is
referred to as the '' principal Act''. By Section 2 of Act XIV, the words '' for a period of three years'' are substituted in Sub-Section 3 of Section 1
of Act XXV, for the words '' for the period of one year''. Sections 3 to 7 of Act XIV introduce various other amendments in Act XXV Section 12
of Act XIV enacts:.
The principal Act shall be deemed to have continued in force until the date of coming into force of this Act and the principal Act as amended by
this Act, shall continue in force for the period specified in Sub-Section 3 of Section 1 of the principal Act as amended by this Act.
Section 12 of Act XIV enacts:
(1) Any proceeding under the principal Act which has been disposed of between the 27th September 1956 and the date of coming into force of
this Act on the footing that the principal Act was not in force at the relevant time, shall be re-opened and disposed of in accordance with the
provisions of the principal Act.
(2) Any cultivating tenant who has been evicted from any land between the dates referred to in Sub-Section 1 on the footing that the principal Act
was not in force at the relevant time, shall, on application, be entitled to be restored to the possession of such land on the same terms as those
applicable to the possession of it under the principal Act.
Original Suits Nos. 137, 190, 192 and 228 of 1957, were instituted in the lower Court by landlords for recovery of possession of lands from
their tenants. In each of those suits, the Defendant pleaded that he was a cultivating tenant as the term was defined in Act XXV and that, under the
Act as amended by Act XIV, the Defendant was entitled to continue in possession until 27th September 1958. Original Suit No. 188 of 1957, on
the file of the lower Court was a suit by the landowner for a permanent injunction restraining the Defendant from interfering with the Plaintiff''s
possession of the lands described in the plaint, The Plaintiff contended that the Defendant was a ''mattuvaramdar'' and not a tenant. The Defendant
pleaded that he was a cultivating tenant entitled to the protection of Act XXV as amended by Act XIV.
In each of these cases, the Plaintiff pleaded, among other things, that since Act XXV had expired with the 26th September 1956, and Act XIV
was enacted on the 1st October 1956, Act XIV could not legally amend, or extend the duration of, Act XXV. The learned District Munsif agreed
with the contentions of the Plaintiff and, acting under the proviso to Section 113, CPC Code, referred to this Court for its opinion the question
whether he had jurisdiction to pass a decree for eviction in the suits in which eviction was sought. Despite the wide range of the reference, the only
question argued before us was whether Act XXV as amended by Act XIV is in force in the State of Madras.
A new law enacted by the Legislature of a State or by Parliament ordinarily takes effect from the date of the enactment of the law or from such
future date as might be stated in the law or in the notification made by an authority designated in the law in that behalf. But, if the Legislature
considers it necessary or expedient to do so, it might cause the new law to have operation with effect from an earlier date. That generally happens
in regard to Finance Acts. New taxes proposed and approved by the Legislature as part of the budget proposals of the Government are generally
levied with effect from the commencement of the financial year. But the Finance Act under which the Government acquires authority to collect
taxes is generally not enacted until after the expiry of a few weeks from the commencement of the financial year. In those cases, the Finance Act
authorises the imposition of the new taxes with effect from the commencement of the financial year, that is to say, retrospectively. It occasionally
happens that, during the middle of a financial year, a revised budget is introduced in and passed by the Legislature. In those cases, a new Finance
Act is passed amending the Finance Act passed in the beginning of the year. The amendments are ordered by the Legislature to have operation
with effect from earlier dates during the financial year or from the commencement of the. financial year. On the 10th September 1931, for example,
Mr. Philip Snowden (as he then was) introduced in the British House of Commons a revised budget for 1931-32, necessitated by what he
considered the immediate need for balancing Britain''s budget. The imposition of fresh taxes of all kinds was proposed and was approved by
Parliament. The Finance (No. 2) Act, 1931 (21 and 22 Geo. 5) Ch. 49, enacted on 5th October 1931, to give effect to the budget proposals
increased the customs and excise duties on several commodities with effect from the 11th day of September 1931, and the rate of income tax with
effect from the commencement of the financial year. Paragraph (f) of Sub-Section 3 of Section 32 of the income tax Act, 1918, which was in
existence immediately before the enactment of the Finance (No. 2) Act, 1931, gave relief from income tax in respect of life insurance premiums
paid by the Assessee. That paragraph in the income tax Act, 1918, was by Finance (No. 2) Act, 1931, repealed with effect from the 6th April
1931. In the meantime, that is to say, between the 6th April 1931 and 5th October 1931, relief had been granted to Assessees in respect of
insurance premiums. Section 8 (2)(b) of Finance (No. 2) Act, 1931, directed that the amount of relief so given should be recovered from the
Assessees.
Notwithstanding all the energetic measures taken to balance the budget, withdrawal of foreign money from the Bank of England continued and
the British Government decided to abrogate the Gold Standard. For that purpose, legislation was necessary. Under Sub-Section 2 of Section 1 of
the Gold Standard Act, 1925, the Bank of England was bound, so long as Sub-Section 1 of Section 1 of the Act was in force, to exchange notes
into gold. On the 18th September 1931, the. British Government instructed the Bank of England not to exchange notes into gold, that is to say, to
disregard its obligations under Sub-Section 2 of Section 1 of the Gold Standard Act. Acting on that authority, the Bank of England refused to sell
gold at the coinage price. On the 21st September 1931, the Government went to the House of Commons and asked for the passage, through all its
stages in one day, of a Bill abrogating the Gold Standard. The Bill was enacted the same day, namely, 21st September 1931. Sub-Section 1 of
Section 1 of the Act (Gold Standard (Amendment) Act, 1931) said that Sub-section (2) of Section 1 of the Gold Standard Act shall cease to have
effect notwithstanding that Sub-Section 1 of the said section remained in force. The Bank of England was thereby relieved of its obligation to sell
gold at the coinage price. That was legislation of the ordinary type, that is to say, legislation which took effect from the date on which the Act was
placed on the statute book. But it was further necessary to legalise the refusal of the bank, after the 18th September 1931, and until the
commencement of the Gold Standard (Amendment) Act, to pay put gold. For that purpose, the Gold Standard (Amendment) Act had to take
effect from the 19th September 1931. That was achieved by Sub-Section 2 of Section 1 of the Gold Standard (Amendment) Act, 1931, which is
in these terms:
The Bank of England are hereby discharged from all liabilities in respect of anything done by the bank in contravention of the provision of the said
Sub-Section 2 at any time after the eighteenth day of September, nineteen hundred and thirty-one, and no proceedings whatever shall be instituted
against the bank or any other person in respect of anything so done as aforesaid.
Sir IVOR JENNINGS thus described what the British Parliament did:
The Parliament of 1931 gave ex post facto legality to the illegal refusal of the Bank of England (under the illegal authority of the Cabinet) to convert
paper currency into gold. "" Law and the Constitution "" by W. Ivor Jennings, III Edition, page 137
Within the sphere of legislation allotted to it, a Legislature may make a new law and direct that such law take effect from a date anterior to the
enactment of the law; may amend an existing law and may direct that the amendments have operation with effect from a date earlier than the
enactment of the Amending Act; and may repeal an existing law and direct the repeal to have retrospective effect with the consequence that
benefits derived under the law thus repealed have to be given up or liabilities incurred under the law thus repealed get discharged with effect from
the date of retrospective operation. There is one other form in which the power of a Legislature to legislate retrospectively may manifest itself. The
Legislature has power, by a later Act, to revive or re-enact a law which, by reason of its being temporary legislation, had ceased to be in force at
the time of the enactment of the subsequent Act. The main question for decision in these references is whether the Legislature has, by Act XIV,
effectively exercised its power to revive Act XXV of 1955 and keep it in force from the 27th September 1955 to the 30th September 1956.
The Legislature''s power to revive and keep in force a temporary Act which has expired by efflux of time is, if we may say so with respect,
expressly recognised and left untouched by the decision of the Supreme Court in Jatindra Nath Gupta v. The Province of Bihar and Ors. (1949)
F.C.R. 595, 606, the authority relied on by the learned District Munsif in his Orders of Reference and by the landlords'' learned Counsel in this
Court. Since that decision is basic to any discussion of the power of a Legislature to amend and extend the duration of an Act which has ceased to
be in force by efflux of time, it is necessary that we examine the faets of that case and ascertain clearly the scope and limitations of the principles
formulated in it.
The Bihar Maintenance of Public Order Act became law on the 16th March 1947. Sub-Section 3 of Section 1 of the Act declared that it
would remain in force for a period of one year from its commencement. To that Sub-section was, however, added a proviso that, on resolution to
that effect being passed by the Bihar Legislature, the Provincial Government might, by notification, direct that the Act would remain in force for a
further period of one year, with such modifications, if any, as might be specified in the notification. Acting under the proviso and resolutions passed
by both Houses of the Bihar Legislature, the Government of Bihar issued a notification on the 11th March 1948, extending the application of the
Act for a further period of one year. On the 15th March 1949, Bihar Act v of 1949, being an Act to amend the Bihar Maintenance of Public
Order Act, 1947, was passed. By that Act, the words ''till the 31st March 1950'' were substituted for the words ''for a period of one year from
the date of its commencement'', in Sub-Section 3 of Section 1 of the Bihar Maintenance of Public Order Act, 1947. Their Lordships (KANIA,
C.J., MAHAJAN and MUKHERJEA, JJ.) held that the power conferred by the Bihar Maintenance of Public Order Act on the Provincial
Government (on a resolution being passed by both Houses of the Legislature) to extend the period of operation of the Act, constituted invalid
delegation of legislative power and that, therefore, the Act ceased to be in force after the 15th March 1948. On the 15th March 1949, the Bihar
Legislature purported, by Bihar Act v of 1949, to amend the Bihar Maintenance of Public Order Act, 1947, so as to extend its duration till the
31st March 1950. In regard to that purported exercise of power to amend the Aet which had expired, KANIA, C.J., said:
Bihar Act v of 1949 is an amending Act. It is not a new Act. It purports only to amend the Bihar Maintenance of Public Order Act, 1947. That
Act, which was a temporary Act, as its duration was fixed for one year by the Act itself, came to an end when the first year expired. The result is
that, when the Bihar Amending Act v of 1949 was passed, there was no Bihar Maintenance of Public Order Act, 1947, in operation in the
Province which could be amended.
That opinion was concurred in by their Lordships MAHAJAN and MUKHERJEA, and it was held that the Bihar Maintenance of Public
Order Act had ceased to be in force on and from 16th March 1948, and that Bihar Act V of 1949, represented an effort to amend a dead Act,
which, under the law, was infructuous.
The central fact to keep in mind in understanding and applying the principles laid down in Jatindra Nath Gupta v. The Province of Bihar and
Ors. (1949) F.C.R. 595 is that the Bihar Maintenance of Public Order Act, 1947, was not in force when Bihar Act v of 1949 was enacted and
that the Legislature, while it enacted Bihar Act v of 1949, acted in the belief that Bihar Act v of 1947 was in force and purported to amend it. The
position would have been different if the Legislature were aware, when it enacted Bihar Act v of 1949, that Bihar Act v of 1947 had ceased to be
in force and had revived or re-enacted Bihar Act v of 1947 so as to keep it in force on the date of the commencement of Bihar Act v of 1949. In
that event, the Legislature would, by Bihar Act v of 1949, be exercising its well-recognised power of amending an existing Act and Bihar Act v of
1949 could not be held inoperative. The point has indeed been placed beyond possibility of misunderstanding, if we may say so with great respect,
by MUKHERJEA J. (as his Lordship then was) in the following passage occurring at. the close of his Lordship''s judgment at page 643:
It is certainly competent to the Legislature in exercise of its plenary powers to revive or recenact a legislation which has already ezpired by lapse of
time. The Legislature is also competent to legislate with retrospective effect; but neither of these things seems to have been done in the present
case. The Legislature proceeds on the footing that the old Act was alive at the date when the new Act was passed, and the new Act merely
purports to amend one of the provisions of the old Act. There could be no amendment of an enactment which is not in existence and from the fact
that the Legislature purports to amend an Act, it could not be held as a matter of construction that the intention of the Legislature was to renew a
dead Act or make a new enactment on the same terms as the old with retrospective effect.
The same point, if we may say so with respect, was expressed in different words by MAHAJAN, J. (as his Lordship then was) in the following
passage at page 628:
Act V of 1949 enacted an amendment in the original Act of 1947, which haft- died a natural death on the 16th March 1948. Unless that Act was
revived, no amendment made in it could be of any effect. The only apt manner of reviving the expired Act was by enacting a fresh statute or by
enacting a statute expressly saying that that Act is herewith revived.
Jatindra Nath Gupta''s Case (1949) F.C.R. 595, thus, recognises that the Legislature has power to revive or re-enact a temporary statute
which has expired by efflux of time and keep the statute in force, extend its duration and amend it in such particulars as the Legislature considers
necessary and expedient: In order that a subsequent Act may have the effect of reviving a statute which has expired by efflux of time, it is necessary
that the subsequent Act should show on its face the Legislature''s consciousness that the earlier Act has expired and that the later Act should
express clearly the Legislature''s intention to revive the expired Act. A mere statement that the earlier Act is amended so as to extend the period of
its operation is not an effective expression of the intention of the Legislature to revive the Act which has expired.
The next case relied on by the Petitioner''s learned Counsel in support of the proposition that Act XIV is not effective to amend or extend the
duration of Act XXV is In Re: Kalyanam Veerabhadrayya, . The Madras Maintenance of Public Order Act (Act I of 1947), came into force on
the 12th March 1947. Under Sub-clause 4 of Section 1 of the Act, it remained in force for a period of one year. That sub-clause, however,
contained a further paragraph empowering the Provincial Government, from time to time, by notification in the Fort St. George Gazette, to extend
the continuance of the Act for a further period or periods not exceeding one year in the aggregate if in their opinion it was expedient to do so.
Before the expiry of the period of one year from the commencement of the Act, the Provincial Government by notification extended the duration of
the Act for a further period of one year commencing from 12th March 1948. In 1948, the Madras Legislature enacted Madras Act XVII of 1948,
by which Madras Act I of 1947 was amended by substituting for the words ''for a further period or periods not exceeding one year in the
aggregate'' the words ''for a further period or periods not exceeding three years in the aggregate'' The Amending Act was placed on the statute
book on the 17th August 1948. The Government of Madras published a notification extending the period of the Act (Act I of 1947) by a year
from 12th March 1949. The decision of the Supreme Court in Jatindra Nath Gupta''s Case (1949) F.C.R. 595, was pronounced on the 28th May
1949. That undoubtedly caused doubts to arise regarding the validity of the two notifications issued by the Government of Madras extending the
continuance of Madras Act I of 1947 with effect on and from 12th March 1948, and the 12th March 1949 respectively. The Legislature of the
Province not being in session, the Governor of Madras issued Madras Ordinance No. 1 of 1949 for the removal of doubts regarding the validity of
the continuance of Madras Act I of 1947. Clause 2 of the Ordinance said:
It is hereby declared that the Madras Maintenance of Public Order Act, 1947 (hereinafter referred to as the said Act), remained in force on
and from the 12th day of March 1948, and shall continue to remain in force so long as this Ordinance remains in operation, and that the said Act
shall have effect and always be deemed to hate had effect, as if Section 1, Sub-Section 4, thereof, had been omitted.
By Clause 4 of the Ordinance, a further amendment was made in Madras Act I of 1947. The main question presented for decision in In Re:
Kalyanam Veerabhadrayya, was, whether by reason of the Ordinance, Madras Act I of 1947, continued in force until the 12th March 1950. That
question was answered by this Court in the negative. Following Jatindra Nath Gupta''s Case(l), this Court held that the Provincial Legislature could
not legally authorise the Government of Madras to extend the duration of the Act by a notification. It followed that Act I of 1947, was not in force
when Madras Ordinance No. 1 of 1949 was promulgated. The Ordinance purported to declare and amend Madras Act I of 1947. this Court held
that, in order that anything might be declared by the Legislature in regard to a statute or in order that an amendment might be made in the statute, it
was necessary that the statute should be in force on the date on which the Act which purported to declare or amend was placed on the statute
book. The declaration by the Ordinance that Madras Act I of 1947 continued in force on and from the 12th day of March 1948, merely betrayed
the Legislature''s ignorance of the legal position. As for the intended amendment, nothing that does not exist can be amended. In that view, the
Court held that Madras Ordinance No. l of 1949 was ineffective either to amend or to extend the duration of Madras Act I of 1947. In Re:
Kalyanam Veerabhadrayya, , again, leaves unaffected the proposition that the Legislature of a State, acting within the sphere allotted to it by Part
XI of the Constitution, may revive or re-enact a temporary Act, which has ceased to be in force by efflux of time, and, thus keeping it alive,
effectively extend its duration and amend it.
The question for decision before us is whether, by Sections 8 and 12 of Act XIV of 1956, the Act has effectively revived Act XXV of 1955
and kept it in force from the 27th September 1955 to the 1st October 1956. If the Act was thus effectively in force on the 1st October 1956, the
Legislature was competent by Act XIV to amend Act XXV of 1955, and extend its duration. Section 8 of Act XIV of 1956, enacts ''the principal
Act shall be deemed to have continued in force until the date of coming into force of this Act. ...''The language used clearly shows that the
Legislature was aware that the Act was not in force on and after the 27th September 1956. The language further adequately expresses the
intention of the Legislature to revive the Act and continue it in force from the moment of its ceasing to be in force by efflux of time. The central
word that enables these purposes to be achieved, is ''deemed''.
In the vocabulary of the draftsman, ''deemed'' is a term of art which expresses an intention to create and keep in being, by a legal fiction, that
which, in the ordinary course of law, did not or would not exist in particular, the word ''deemed'' is used whenever it is intended to give
retrospective operation to the provisions of a statute. Madras Act XXIII of 1954, for example, which was placed on the statute book on the 1st
September 1954, states that it shall be deemed to have come into force on the 1st May 1953. What the Act thereby does, is, by a legal fiction, to
render lawful that which had been unlawful between 1st May 1953, and the 1st September 1954. Things which happen in accordance with the Act
subsequent to the 1st September 1954, are lawful in the ordinary course of law, that is to say, without the need for any legal fiction as to the state
of the law. Things which were unlawful before the 1st September 1954, are made lawful by a retrospective change effected in the state of the law.
Not merely could a new law be thus rendered effectively retrospective by the use of the term '' deemed'', but amendments in existing statutes could
also be caused to operate retrospectively by the use of the word ''deemed''. Sub-Section 2 of Section 1 of Madras Act XXXIV of 1954, for
example, states that Sections 2 and 3 of the Act shall be deemed to have come into force on the 19th April 1949. The Act itself was placed on the
statute book on the 19th January 1955. The Madras Estates (Abolition and Conversion into Ryotwari) Act, 1948, was thus amended with
retrospective effect by the use of tarm ''deemed''. The Central Legislature too uses the term ''deemed'' for achieving a similar purpose. Please see
for example Section 28-A of the Provincial Insolvency Act (V of 1920).
We shall find the same use made of the word ''deemed'' by draftsman in other parts of the Commonwealth too.
In E.H. Battat v. The King (1951) A.C. 519, 530, the Privy Council had to consider the effect of Section 5 of the Indemnity and Validating
Ordinance of 1946, issued by the Governor of Singapore. Certain Regulations were made in Singapore in December 1945, in exercise of powers
conferred on the person who made the Regulations, by the Military Administration Proclamation which had been made in Kandy on August 15,
1945, by Lord Louis Mount-batten, Supreme Allied Commander, South-East Asia. The Appellant before their Lordships of the Privy Council had
been convicted for violation of the provisions of the Regulations. The Regulations would be invalid if the Proclamation made by Lord Louis
Mountbatten, referred to as the Kandy Proclamation, was without jurisdiction. u/s 40 of the Singapore Colony Order in Council, 1946, the
Governor of Singapore had authority to make laws for the peace, order and good government of the colony. Pursuant to the said section, the
Governor on April 1, 1946, enacted the Indemnity and Validating Ordinance, 1946. Section 5 thereof read:
All laws, proclamations, orders, rules, regulations and legislative acts whatsoever made or issued during the war period by or with the assent of any
British or Allied military authority shall be deemed to have been validly made from the date of promulgation in the area concerned notwithstanding
that any such law, proclamation, order, rule, regulation or legislative act may have repealed or amended or been inconsistent with any law
previously in force.
For the purposes of the appeal, their Lordships of the Privy Council assumed that the Kandy Proclamation was invalid. That being so, the
regulations under which the Appellant was convicted would be invalid, unless the Proclamation and the Regulations were saved by Section 5 of the
Indemnity and Validating Ordinance, 1946. Their Lordships held:
... that the words ''shall be deemed to have been validly made from tie date of promulgation'' clearly indicate an intention to give legal efficacy to
such proclamations from the date of their promulgation onwards and beyond April 1, 1946. The draftsman here is clearly envisaging the possibility
of existing proclamations de facto in force being invalid in law and is intending to give them the force of law.
Where a law promulgated is invalid for want of authority in the person making the law and subsequently the Legislature competent to make
laws on the subject in the area for the period covered by the invalid law enacts a statute which says that the law shall be deemed to have been
validly made from the date of its promulgation, then the law which did not exist de jure from the date of its promulgation gets validly re-enacted
with effect from the date of its promulgation and continues to be in force for the period for which the subsequent Act enacted by the competent
Legislature keeps the law in force. In the case before us, Act XXV of 1955, was not in force from the 27th September 1955 to the 30th
September 1956. Section 8 of Act XIV, by enacting that Act XXV shall be deemed to have continued in force, effectively revived and re-enacted
Act XXV and kept it in force at the time of the commencement of Act XIV of 1956.
We agree with respect with the views expressed in Kedarnath Gupta v. Nagindra Narayan AIR 1954 Pat. 97 by the Patna High Court
regarding the construction of the words ''shall be deemed to have continued in force''.
We hold that Madras Act XXV of 1955, as amended by Madras Act XIV of 1956, is in force in the State of Madras and will continue in
force for the period stated in Section 1, Sub-Section 3 of Madras Act XXV of 1955, as amended by Act XIV of 1956.
For the sake of completeness, we may note before we conclude that we have not referred to the dissent expressed by the Supreme Court in
Sardar Inder Singh Vs. The State of Rajasthan, from the propositions relating to the competence of the Legislature of a State to confer power on
the Government of the State to extend the life of a temporary enactment. The particular part of the principles laid down in Jatindra Nath Gupta''s
Case (1949) F.C.R. 595 is not relevant for the purpose of these References. We may note also that in E.H. Battat v. The King (1951) A.C. 519,
the Privy Council did not have to consider a prohibition such as we have in Article 20 (1) of our Constitution against the conviction of any person
except for violation of a law in force at the time of the commission of the act charged as an offence. If the Kandy Proclamation considered in that
case were invalid, the conviction of the Appellant before their Lordships could not, under a Constitution like ours, be validated by ex post facto
legislation validating the Proclamation. That question, again, is not relevant for the purposes of the discussion of the questions that arise on these
References.
Because the learned District Munsif considered that the duration of Act XXV had not been validly extended by Act XIV of 1956, he said that
the rules framed under the Act would also cease to be in operation. Since we have held that Act XXV of 1955 as amended by Act XIV of 1956
is in force, the ground taken by the District Munsif in regard to the validity of the rules ceases to be sustainable.
These References were made before we and our learned brother GANAPATIA PILLAI J., sitting as a Full Bench, pronounced judgment in
Writ Petition No. 644 of 1957. All the points raised in the Orders of Reference relating to the constitutional validity of Madras Act XXV of 1955,
Madras Act XIV of 1956 and Madras Act XXIV of 1956, which have not been dealt with in this judgment, have been finally disposed of by the
judgment pronounced by the Full Bench.
The learned District Munsif will hear and decide the suits in accordance with the opinions expressed in this judgment. There will be no order as
to costs on these References.