REGINA vs ST. ALOYSIUS HIGHER ELEMENTARY SCHOOL & ANR.

The Supreme Court held that the rules framed under the Madras Elementary Education Act, 1920, specifically Section 56(2)(h), were not statutory rules but merely administrative instructions. The Court found that the rules in Part II did not satisfy the conditions for being considered statutory as they did not refer to any sections of the Act and lacked prior publication. However, the Government retained the power to establish conditions for recognition and aid outside the Act, which could be enforced against school managements. The appellant's suit for mandatory injunction was thus not maintainable under the statutory framework.