HUKAM CHAND ETC, vs UNION OF INDIA & OTHERS(with connected appeal)

The Supreme Court ruled that the Central Government exceeded its authority under Section 40 of the Displaced Persons (Compensation and Rehabilitation) Act, 1954, by retroactively amending Rule 49 to define 'agricultural land' as land situated in a rural area. The Court held that there is no express or implied power in Section 40 allowing for retrospective rule-making, and thus the amendment was deemed ultra vires. The validity of rules laid before Parliament does not prevent judicial scrutiny if they do not conform to the Act.