Supreme Court Ruling 2025: Key Legal Insights
Case Title: M/S SRS Travels by its Proprietor KT Rajashekhar Versus The Karnataka State Road Transport Corporation Workers And Others (2025)
Main Context:
The case M/S SRS Travels v. Karnataka State Road Transport Corporation Workers & Others is about the cancellation of the Karnataka Contract Carriages (Acquisition) Act, 1976 (KCCA Act) and the legal issues that followed. It questions whether the cancellation was legally valid, who has the power to issue permits, and whether the Karnataka State Government had the authority to make such a decision.
The Supreme Court Ruling 2025 reaffirmed that the repeal of the KCCA Act did not require fresh Presidential assent, clarifying the authority of the State Legislature in such matters. The case primarily dealt with the constitutional validity of the repeal, delegation of permit-granting powers, and the authority of the State Legislature.
Enactment of the KCCA Act, 1976
The Karnataka Contract Carriages (Acquisition) Act, 1976 (KCCA Act) was introduced to take over private contract carriages and transfer them to State-owned Road Transport Corporations (RTCs) like KSRTC. The goal was to bring private transport under government control for better regulation and efficiency.
Supreme Court's Previous Rulings
The KCCA Act was challenged in court but was upheld by the Supreme Court in the State of Karnataka v. Ranganatha Reddy (1978). The Court later confirmed this decision in Vijayakumar Sharma v. State of Karnataka (1990), stating that the Act followed the principles of Article 39(b) and (c) of the Indian Constitution, which promote equal resource distribution and prevent wealth concentration.
Repeal of the KCCA Act & Legal Disputes
To improve public transport and allow private buses to operate, the KCCA Act was canceled through the 2003 Repeal Act. This made it easier for private operators to get permits and run their services.
After the cancellation, private bus operators applied for permits, which were given by STA and RTA Secretaries. However, KSRTC and its workers objected, stating that:
The cancellation needed approval from the President again.
The permits should be issued by a group of officials, not just secretaries.
Karnataka High Court Decisions:
Single Judge Ruling (17th November 2004):
The 2003 Repeal Act was found unconstitutional. The court also declared Rules 55 and 56 of the KMV Rules invalid because they allowed Secretaries to issue permits.
Division Bench Ruling (28th March 2011):
The court upheld the validity of the 2003 Repeal Act, stating that the legislature could repeal the KCCA Act without needing fresh Presidential assent. However, the court ruled that the delegation of permit-granting power to STA and RTA Secretaries was wrong. This decision was based on the view that permit issuance was a quasi-judicial function that should be done collectively.
Court’s Observations
Legality of the 2003 Repeal Act :
KSRTC contended that repealing the KCCA Act was unconstitutional because it allegedly overruled Supreme Court rulings in Ranganatha Reddy (1978) and Vijayakumar Sharma (1990). However, the Supreme Court rejected this argument, Stating that:
The earlier rulings only affirmed the validity of the KCCA Act at the time of enactment and did not prevent the Legislature from modifying or repealing it in response to policy changes.
Fresh Presidential assent was not required for the repeal, as a repealed statute nullifies the previous law rather than creating a new legal framework.
The repeal was enacted under Entry 57 of List II (Taxation), granting the State independent legislative competence, whereas the original KCCA Act was enacted under Entry 42 (Acquisition and Requisition of Property).
The repeal was a policy decision aimed at liberalizing the transport sector, rather than an attempt to override judicial rulings.
Supreme Court's Verdict
A bench of Justice Vikram Nath and Justice PB Varale held that a new Act repealing an old Act does not require Presidential Assent under Article 254 of the Constitution. The Court further stated that:
Repealing an Act does not recreate the legal framework but only nullifies the old Act’s provisions.
Since the repeal falls within the legislative competence of the State, fresh Presidential approval is not necessary.
The 2003 Repeal Act was valid, as it was meant to correct past legislative issues and adapt the transport system to modern needs.
Conclusion
The case of M/S SRS Travels v. KSRTC Workers & Ors. was a landmark decision in transport regulation and legislative power. The Supreme Court reinforced the State’s legislative competence in repealing outdated transport laws and clarified that repeal does not necessitate fresh Presidential assent. However, the Court also emphasized that permit-granting powers should not be delegated to individual secretaries due to their quasi-judicial nature, ensuring fair adjudication in transport regulation.
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