What was challenged in this case?

A notification that extended municipal tax provisions to a new area without giving residents a chance to object or be heard.

Was the notification valid delegation?

No. It modified essential policy by removing the hearing requirement, which went beyond the power to extend sections with minor modifications.

Why is the right to object crucial here?

Because the parent Act treated notice and hearing before taxation as an essential feature, not a removable detail.

What did the Supreme Court finally hold?

Delegation is allowed within limits, but the notification was ultra vires for altering essential policy; it was struck down.

Rajnarain Singh v. Chairman, Patna Administration Committee

Quick Summary

Patna extended municipal taxes to a new area by notification. But it skipped the parent Act’s essential step: giving residents notice and a chance to object. The Supreme Court said: you may delegate power to extend and tweak, but you cannot cut out core policy safeguards. The notification was ultra vires and invalid.

Hero image for Rajnarain Singh v. Patna Administration Committee

Issues

Was the purpose of the Act defeated by omitting the residents’ right to object and be heard?
Was the notification ultra vires as an excessive delegation of legislative power?

Rules

Section 3(1)(f) allowed the administration to extend provisions of the Bengal Municipal Act, 1884 to Patna “with modifications.”
But an essential feature—no taxation without prior notice and hearing—could not be removed by notification.
Delegation is valid within limits; it cannot permit changing core policy of the parent Act.

Facts — Timeline

Background: Residents lived outside earlier Patna municipal limits; no municipal taxes applied.

Tax Demand: Asked to pay municipal taxes for 1 Apr 1951–31 Mar 1952.

Legal Route: Government issued notifications under the Patna Administration Act, 1915 using Sections 3(1)(f) & 5.

Challenge: Rajnarain Singh (Secretary, Ratepayers’ Association) argued the notifications were bad for delegating legislation and skipping hearing provisions.

Core Omission: Sections guaranteeing residents an opportunity to object were left out in the extension.

Case timeline for Rajnarain Singh v. Patna Administration Committee

Arguments

Appellant (Rajnarain Singh)

Notification removed a vital safeguard (notice & hearing).
That change of policy is beyond delegated power.
Hence, the notification is ultra vires and invalid.

Respondent (Administration)

Section 3(1)(f) allowed extension with modifications.
Notification lawfully extended tax provisions to the area.
Hearing provisions were not essential to extension.

Judgment

The Supreme Court held that while delegation to extend and adapt law is valid within limits, the Patna notification crossed the line. It cut out an essential feature—the resident’s right to object before new taxation. That altered the policy of the parent Act. Therefore, the notification was ultra vires and bad.

Ratio

Modification ≠ Policy Rewrite. Delegated legislation may fill in details, but it cannot delete core safeguards (notice & hearing) that reflect legislative policy. Such a notification is ultra vires.

Why It Matters

Draws the boundary between valid delegation and excessive delegation.
Protects citizens’ procedural right to be heard before new taxes.
Guides drafters on what counts as an essential feature of a statute.

Key Takeaways

Delegation allows details; not policy change.
Hearing before taxation is an essential safeguard.
Notifications skipping core safeguards are ultra vires.
Courts examine what was removed, not just how it was done.

Mnemonic + 3-Step Hook

Mnemonic: “HOP” — Hearing is essential, Omit = ultra vires, Policy can’t be rewritten.

Spot the Safeguard: Does the parent Act require notice/hearing?
Check the Notification: Did it delete or dilute that safeguard?
Verdict: If yes, it likely travels beyond delegated power.

IRAC Outline

Issue	Validity of a notification extending tax provisions while omitting residents’ right to object; scope of delegated power.
Rule	Delegation may extend law with modifications but cannot alter essential policy safeguards (notice & hearing).
Application	Omission of hearing provisions changed the statute’s policy on imposing new taxes; exceeded Section 3(1)(f).
Conclusion	Notification was ultra vires; invalid. Delegation is permissible only within policy-preserving limits.

Glossary

Delegated Legislation: Law made by the executive under authority given by Parliament/Legislature.
Ultra Vires: Beyond legal power; action exceeds the authority granted by law.
Essential Feature: A core policy element of a statute that cannot be removed by delegated rules/notifications.