M/S. WEST RAMNAD ELECTRIC DISTRIBUTION CO. LTD. vs STATE OF MADRAS

The Supreme Court upheld the validity of the Madras Electricity Supply Undertakings (Acquisition) Act, 1954, stating that the Madras Legislature had the competence to enact a law with retrospective effect to validate actions taken under the earlier ultra vires Act of 1949. The Court clarified that the provisions of the 1954 Act, particularly Section 24, were intended to validate prior notifications issued under the invalid Act, thus ensuring continuity of possession. The Court also ruled that Article 31(1) of the Constitution permits retrospective legislation, distinguishing it from Article 20(1).