UTTAM BALA RAVANKAR vs ASSTT. COLLECTOR OF CUSTOMS & CENTRAL EXCISE, GOA & ANR.

The Supreme Court held that the Lt. Governor of Goa, Daman and Diu acted ultra vires by passing an order on November 6, 1963, under the Goa, Daman and Diu (Administration) Removal of Difficulties Order, 1962, instead of under Section 8 of the Goa, Daman and Diu (Laws) Regulation, 1962. The Court clarified that Section 8 authorizes the removal of difficulties in implementing laws and that the definition of 'Central Government' in the General Clauses Act includes the Lt. Governor. Consequently, the procedure to be followed in criminal proceedings should adhere to the Portuguese Criminal Procedure Code rather than the Indian Code of Criminal Procedure.