State of Uttar Pradesh v Singhara Singh and Ors.
Rule established
Where a statute prescribes a particular manner or mode for doing an act (such as recording a confession or statement before a specified authority), that act must be done in that manner alone, and no other; a magistrate empowered to record a statement in a particular way cannot delegate that function or record it through an unauthorised alternative procedure.
Facts
- A statutory provision empowered a specific authority, a magistrate, to record a statement or confession in a particular prescribed manner
- The recording of the statement in question had been carried out through a departure from this prescribed procedure, raising the question of whether the resulting record was valid and admissible
Issue
- Where a statute prescribes a specific mode for performing an act, can that act be validly performed through a different mode or procedure, or by delegation to another person not authorised by the statute.
Held
- The Supreme Court held that it is a well-established principle that where a statute confers a power to be exercised in a particular manner, and that power is exercised in a manner other than that prescribed, the exercise of the power is invalid
- This principle equally prohibits delegation of a function to a person not authorised by the statute to perform it, even if that person is otherwise closely connected to the process
- The specific method prescribed excludes all other methods by necessary implication; the maxim "expressio unius est exclusio alterius" (the expression of one thing excludes others) informed this reasoning
- On the facts, the departure from the prescribed manner invalidated the resulting record, and it could not be relied upon in the manner the prosecution or party sought to use it
Ratio Decidendi
Where a statute specifically prescribes a particular manner for performing an act or exercising a power, that manner is exclusive; any departure, including through delegation to an unauthorised person, renders the resulting act invalid, since the specific prescription impliedly excludes all alternative modes of compliance.
How to use it in an exam
- Foundational authority for the "prescribed mode excludes other modes" principle, applicable across procedural contexts involving statutory formalities
- Pair with the general discussion on statutory interpretation maxims, particularly expressio unius est exclusio alterius
- Key line: when the legislature specifies how something must be done, that specification is a limit, not merely a suggestion
Source
Source: AIR 1964 SC 358; foundational authority on the principle that a prescribed statutory mode excludes all other modes, cross-verify citation before exam use
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.