Showing posts with label unconstitutional. Show all posts
Showing posts with label unconstitutional. Show all posts

Tuesday, 12 September 2023

Supreme Court: Once A Law Is Declared Unconstitutional ,it shall have retrospective effect

 Then comes the question as to what is

the effect of an amendment of the

Constitution in the two types of cases. So

far 'as pre-Constitution laws are concerned

the amendment of the Constitution which

removes the inconsistency will result in the

revival of such laws by virtue of the

doctrine of eclipse, as laid down in Bhikaji

Narain's case (1) for the pre-existing laws

were not still-born and would still exist

though eclipsed on account of the

inconsistency to govern_ pre-existing

matters. But in the case of post-

Constitution laws, they would be still

born to the extent of the contravention.

And it is this distinction which results

in the impossibility of applying the

doctrine of eclipse to post-Constitution

laws, for nothing can be revived which

never had any valid existence. We are

therefore of opinion that the meaning of the

word "void" is the same both in Art 13 (1)

and Art. 13 (2), and that the application of

the doctrine of eclipse in one case and not

in the other case does not depend upon

giving a different meaning to the word

"void' in the two parts of Art. 13; it arises

from the inherent difference between Art.

13 (1) and Art. 13 (2) arising from the fact

that one is dealing with pre-Constitution

laws, and the other is dealing with post-

Constitution laws, with the result that in

one case the laws being not still-born the

doctrine of eclipse will apply while in the

other case the laws being still born-there

will be no scope for the application of the

doctrine of eclipse. Though the, two clauses

form part of the same Article, there is a

vital difference in the language employed

in them as also in their content and scope.

By the first clause the Constitution

recognises the existence of certain

operating laws and they are declared void,

to the extent of their inconsistency with

fundamental rights. Had there been no

such declaration, these laws would have

continued to operate. Therefore, in the case

of pre- Constitution laws what an

amendment to the Constitution does is to

remove the shadow cast on it by this

declaration. The law thus revives.

However, in the case of the second

clause, applicable to post Constitution

laws, the Constitution does not

recognise their existence, having been

made in defiance of a prohibition to

make them. Such defiance makes the

law enacted void. In their case

therefore there can be no revival by an

amendment of the Constitution, MO

though the bar to make the law is

removed, so far as the period after the

amendment is concerned. In the case

of post- Constitution laws, it would be

hardly appropriate to distinguish

between laws which are wholly void-as

for instance, those which contravene

Art. 31-and those which are

substantially void but partly valid, as

for instance, laws contravening Art.

19. Theoretically, the laws falling

under the latter category may be valid

qua non-citizens; but that is a wholly

unrealistic consideration and it seems

to us that such nationally partial

valid existence of the said laws on the

strength of hypothetical and pedantic

considerations cannot justify the

application of the doctrine of eclipse

to them. All post Constitution laws

which contravene the mandatory

injunction contained in the first part

of Art. 13 (2) are void, as void as are

the laws passed without legislative

competence, and the doctrine of

eclipse does not apply to them. We are

therefore of opinion that the Constitution

(Fourth Amendment) Act cannot be applied

to the Transfer Act in this case by virtue of

the doctrine of eclipse It follows therefore

that the Transfer Act is unconstitutional

because it did not comply with Art. 31 (2),

as it stood at the time it was passed. It will

therefore have to be struck down, and the

petitioner given a declaration in his favour

accordingly.

(emphasis supplied)”

(vii) In the case of State of Manipur (supra),

recently a three-judge Bench of this Court, was

dealing with an appeal against the judgement of

the Manipur High Court which had declared the

Manipur Parliamentary Secretary (Appointment,

Salary and Allowances and Miscellaneous

Provisions) Act, 2012 (Manipur Act No. 10 of

2012) as also the Repealing Act, 2018, as

unconstitutional. Justice L. Nageswara Rao,

speaking for the Bench, observed that where a

statute is adjudged to be unconstitutional, it is

as if it had never been and any law held to be

unconstitutional for whatever reason, whether

due to lack of legislative competence or in

violation of fundamental rights, would be void

ab initio. Paragraph Nos. 22 and 23 of the said

judgment are reproduced hereunder:


“22. Where a statute is adjudged to be

unconstitutional, it is as if it had

never been. Rights cannot be built up

under it; contracts which depend upon it

for their consideration are void; it

constitutes a protection to no one who has

acted under it and no one can be punished

for having refused obedience to it before the

decision was made. Field, J. in Norton v.

Shelby County, observed that “an

unconstitutional act is not law, it

confers no rights, it imposes no duties,

it affords no protection, it creates no

office; it is, in legal contemplation, as

inoperative as though it had never

been passed”.

23. An unconstitutional law, be it

either due to lack of legislative

competence or in violation of

fundamental rights guaranteed under

Part III of the Constitution of India, is

void” ab initio. In Behram Khurshid

Pesikaka v. State of Bombay, it was held

by a constitution bench of this Court that

the law-making power of the State is

restricted by a written fundamental law

and any law enacted and opposed to the

fundamental law is in excess of the

legislative authority and is thus, a nullity.

A declaration of unconstitutionality

brought about by lack of legislative

power as well as a declaration of

unconstitutionality brought about by

reason of abridgement of fundamental

rights goes to the root of the power

itself, making the law void in its

inception. This Court in Deep Chand v.

State of Uttar Pradesh & Ors. summarised

the following propositions:

“(a) Whether the Constitution

affirmatively confers power on the

legislature to make laws subject-wise or

negatively prohibits it from infringing any

fundamental right, they represent only

two aspects of want of legislative power;

(b) The Constitution in express terms

makes the power of a legislature to make

laws in regard to the entries in the Lists

of the Seventh Schedule subject to the

other provisions of the Constitution and

thereby circumscribes or reduces the said

power by the limitations laid down in

Part III of the Constitution;

(c) It follows from the premises that a

law made in derogation or in excess

of that power would be ab initio

void…

(emphasis supplied)”

Further after discussing the law laid

down by the previous pronouncements, the

principles were deduced in paragraph no. 28 to

state that a statute declared unconstitutional

by a court of law would be still born and non

est for all purposes. Paragraph 28 of the report

is reproduced hereunder:

“28. The principles that can be deduced

from the law laid down by this Court, as

referred to above, are:

I. A statute which is made by a

competent legislature is valid till it is

declared unconstitutional by a court of law.

II. After declaration of a statute as

unconstitutional by a court of law, it is

non est for all purposes.


III. In declaration of the law, the

doctrine of prospective overruling can be

applied by this Court to save past

transactions under earlier decisions

superseded or statutes held

unconstitutional.

IV. Relief can be moulded by this Court

in exercise of its power under Article 142 of

the Constitution, notwithstanding the

declaration of a statute as

unconstitutional.

(emphasis supplied)”

43. From the above discussion, it is crystal clear

that once a law is declared to be

unconstitutional, being violative of Part-III of the

Constitution, then it would be held to be void ab

initio, still born, unenforceable and non est in

view of Article 13(2) of the Constitution and its

interpretation by authoritative pronouncements.

Thus, the declaration made by the

Constitution Bench in the case of

Subramanian Swamy (supra) will have

retrospective operation. Section 6A of the

DSPE Act is held to be not in force from the

date of its insertion i.e. 11.09.2003.

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO.377 OF 2007

CBI  Vs R.R. KISHORE 

Author: VIKRAM NATH, J.

SEPTEMBER 11, 2023.

Citation:  2023INSC817.

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