STATE OF ORISSA vs CHANDRA SEKHAR SINGH BHOI ETC.

The Supreme Court held that under Article 31-A, proviso 2 of the Constitution of India, a law cannot be considered 'in force' unless it is operational through legislative enactment or delegated authority. The Court found that Chapter IV of the Orissa Land Reforms Act, 1960, which dealt with ceiling limits, was never brought into operation and was repealed by the amending Act 15 of 1965. Consequently, there was no applicable ceiling limit for landholders, and the High Court's ruling that struck down Chapter IV as unconstitutional was overturned.