POURNAMI OIL MILLS, ETC. vs STATE OF KERALA & ANR.

The Supreme Court held that orders made under statutory authority, even without explicit reference to the enabling provision, are deemed valid under that provision, specifically Section 10 of the Act. The Court ruled that industries established before October 21, 1980, are entitled to the promised exemptions for five years, while those set up afterward are not, as they were aware of the changes. Furthermore, the Court recognized the applicability of estoppel for small scale industries that relied on government orders when establishing their businesses, affirming the principle that the state cannot act contrary to its prior commitments.