STATE OF MADHYA PRADESH & ORS. vs TIKAM DAS

The Supreme Court held that subordinate legislation cannot have retrospective effect unless expressly permitted by the statute. Under Section 63 of the Madhya Pradesh Excise Act, 1915, rules can be made effective from a previous date. The Court ruled that the enhanced license fee applies to the balance of stock held by the licensee on March 31, 1964, thus affirming the State's right to levy the fee from April 1, 1964. The appeal was allowed, reversing the High Court's decision.