MISRILAL JAIN ETC. ETC. vs STATE OF ORISSA & ANOTHER

The Supreme Court upheld the validity of the 1968 Act, affirming that legislative power includes the authority to legislate retrospectively, as established in Khyerbari Tea Co. Ltd. v. State of Assam [1964] 5 S.C.R. 975. The Court ruled that the retrospective effect given to the 1968 Act, which deemed actions taken under the 1959 Act as valid, did not violate constitutional principles. Furthermore, the Court clarified that the legislature can validate an enactment if it complies with legal requirements, and that appeals filed beyond the limitation period due to the unconstitutionality of prior Acts can be condoned under Section 12 of the 1968 Act.