Administrative lawDelegated legislationSupreme Court of India

St. Johns Teachers Training Institute v National Council for Teacher Education

AIR 2003 Supreme Court 153320031 min read
The case in brief30-second read
Facts
National Council for Teacher Education (NCTE) issued regulations governing teacher training institutions. St. Johns argued that certain regulations imposed requirements that exceeded the scope of the NCTE Act.
Issue
Do regulations issued by the NCTE that impose requirements beyond those authorised by the enabling Act constitute substantive ultra vires?
Held
The Supreme Court held that delegated legislation must remain within the scope of the parent Act. Regulations that impose conditions or requirements not authorised by the enabling Act are ultra vires and void. The power to regulate does not include the power to impose obligations beyond the regulatory framework Parliament established.
Principle
Delegated legislation (regulations) that exceeds the scope of the parent Act is ultra vires and void.
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Facts

  • National Council for Teacher Education (NCTE) issued regulations governing teacher training institutions
  • St. Johns argued that certain regulations imposed requirements that exceeded the scope of the NCTE Act
  • Challenge on the ground of substantive ultra vires

Issue

  1. Do regulations issued by the NCTE that impose requirements beyond those authorised by the enabling Act constitute substantive ultra vires?

Held

  • The Supreme Court held that delegated legislation must remain within the scope of the parent Act. Regulations that impose conditions or requirements not authorised by the enabling Act are ultra vires and void. The power to regulate does not include the power to impose obligations beyond the regulatory framework Parliament established.

Ratio decidendi

Substantive ultra vires: subordinate legislation is void if it exceeds the scope of the authority conferred by the parent Act. The principle is an application of the rule that delegated power cannot exceed the power delegated.

Exam use

How to use it in an answer

Deploy in ADM-3.3 (Control of Delegated Legislation) for substantive ultra vires. Illustrates that even a statutory regulatory body cannot issue regulations beyond its enabling Act's scope.

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Citation

St. Johns Teachers Training Institute v National Council for Teacher Education AIR 2003 Supreme Court 1533

Reported: AIR 2003 Supreme Court 1533. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.