M/s. KRISHNA BUS SERVICE PVT. LTD. ETC. ETC. vs STATE OF HARYANA & ORS.

The Supreme Court examined the validity of the Punjab Motor Vehicles (Haryana First Amendment) Rules, 1973, which conferred powers of a Deputy Superintendent of Police upon the General Manager of Haryana Roadways. The Court held that this conferral of power violates Article 19(1)(d) of the Constitution as it creates a conflict of interest, given that the General Manager is responsible for the administration of Haryana Roadways, which competes with private operators. The Court ruled that such a provision is contrary to the object and spirit of the Motor Vehicles Act, 1939, and thus struck it down.