GULSHAN & ANR. ETC. vs ZILA PARISHAD & ORS.

The Supreme Court held that the bye-law framed by Zila Parishads under Section 239(2)(E)(a) of the Uttar Pradesh Kshetra Samiti and Zila Parishads Adhiniyam, 1961, which mandated public auction for the trade in carcass utilisation, was valid and did not violate Article 19(1)(g) of the Constitution. The Court distinguished its earlier ruling in State of Maharashtra v. Mumbai Upnagar Gramodyog Sangh, asserting that the bye-law did not create a monopoly and was a reasonable restriction under Article 19(6). The Court directed the State Government to issue licenses to cooperative societies for carcass disposal, thereby modifying the previous auction system.