HARISHCHANDRA vs STATE OF MADHYA PRADESH

The Supreme Court held that the Madhya Bharat Scrap Order was repealed upon the extension of the Indian Scrap Order under the Essential Supplies (Temporary Powers) Amendment Act, 1950, despite the lack of an express repeal. The Court ruled that subordinate legislation does not survive the repeal of its parent statute unless explicitly preserved, leading to the conclusion that the notification dated August 26, 1949, was also invalidated. Furthermore, the Court clarified that the term 'person' in the General Clauses Act includes unincorporated bodies, thus holding the President of the Scrap Dealers Association liable for the actions of the Association.