Krishna Kumar Singh & Anr vs State Of Bihar & Ors

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 re-promulgation of an Ordinance is permissible under exigent circumstances but must not be a mechanical exercise. The validity of the first three Ordinances was assumed, but the subsequent Ordinances were struck down due to inadequate justification by the State of Bihar.