KRISHNA KUMAR SINGH vs STATE OF BIHAR .

The Supreme Court held that laying an Ordinance before the State Legislature is not mandatory under Article 213(2) of the Constitution, and failure to do so does not invalidate the Ordinance. The Court overruled previous decisions in State of Orissa v. Bhupendra Kumar Bose and T. Venkata Reddy v. State of Andhra Pradesh, establishing that an Ordinance cannot create enduring rights for citizens. The Court affirmed that while re-promulgation of an Ordinance is not inherently unconstitutional, it must be justified by the Governor, and benefits under previously promulgated Ordinances must be recognized until they cease to operate.