A) ABSTRACT / HEADNOTE

The Supreme Court judgment in Ch. Tika Ramji & Others, etc. v. The State of Uttar Pradesh & Others, delivered in 1956, addressed the constitutional validity of the U.P. Sugarcane (Regulation of Supply and Purchase) Act, 1953. This judgment examined legislative competence, repugnancy under Article 254, and alleged violations of fundamental rights under Articles 14, 19, and 31 of the Constitution. Petitioners—sugarcane growers—challenged the State’s right to regulate sugarcane supply, arguing infringement of constitutional rights and legislative encroachment upon central powers under Entry 52, List I.

The Court upheld the validity of the Act, recognizing the concurrent legislative powers of both the Centre and States under Entry 33 of List III. It clarified the application of the doctrine of repugnancy and held that the impugned state law did not contravene any parliamentary enactment. Further, it dismissed the challenges to Articles 14 and 19, holding the restrictions imposed by the Act and the associated notifications as reasonable and in public interest.

The judgment played a critical role in defining the Centre-State relationship concerning agricultural raw materials used in industries and clarified the doctrine of legislative competence and repugnancy under the Indian Constitution.

Keywords: Legislative Competence, Repugnancy, Sugarcane Regulation, Fundamental Rights, Entry 33 List III, Article 254.

B) CASE DETAILS

i) Judgment Cause Title: Ch. Tika Ramji & Others v. The State of Uttar Pradesh & Others
ii) Case Number: Petitions Nos. 585, 599, 611, 622, 625, 565, 576 of 1954 and others
iii) Judgment Date: 24th April, 1956
iv) Court: Supreme Court of India
v) Quorum: S. R. Das (C.J.), N.H. Bhagwati, Venkatarama Ayyar, B.P. Sinha, and Jafar Imam, JJ.
vi) Author: Justice N.H. Bhagwati
vii) Citation: 1956 SCR 393
viii) Legal Provisions Involved: Articles 14, 19(1)(c), (f), (g), 31, 301, 254 of the Constitution; U.P. Sugarcane Act, 1953; Essential Commodities Act, 1955; Industries (Development and Regulation) Act, 1951
ix) Judgments overruled by the Case (if any): None
x) Case is Related to which Law Subjects: Constitutional Law, Administrative Law, Agricultural Law, Commercial and Industrial Law

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The Supreme Court deliberated upon a set of constitutional petitions challenging the validity of the U.P. Sugarcane (Regulation of Supply and Purchase) Act, 1953 and two notifications issued under it by the State of Uttar Pradesh. The case centered around whether a State could regulate the supply of agricultural produce (sugarcane) to industries (sugar mills), or whether it was exclusively a central legislative function under Entry 52 of List I. The background involved a series of central and state laws governing sugarcane and sugar, including the Industries (Development and Regulation) Act, 1951, the Essential Commodities Act, 1955, and the Sugarcane Control Orders issued thereunder. The matter raised significant constitutional issues about federalism, fundamental rights, and legislative competency.

D) FACTS OF THE CASE

The petitioners, comprising over 4,700 sugarcane growers from U.P., challenged the 1953 Act and two government notifications dated September 27, 1954 and November 9, 1955, which created assigned zones for sugar mills and compelled procurement through registered co-operative societies where 75% membership thresholds were met. They alleged that these measures violated Articles 14, 19(1)(c), (f), (g), 31 and 301 of the Constitution. The government defended its stance, asserting legislative competence under Entry 33 of List III, a concurrent list subject introduced via the Third Constitutional Amendment Act, 1954, and justified the regulations as reasonable restrictions in public interest.

E) LEGAL ISSUES RAISED

i) Whether the U.P. Sugarcane Act, 1953 was ultra vires the State Legislature in light of Entry 52, List I, and Entry 33, List III.
ii) Whether the State law was repugnant to central laws like the Industries (Development and Regulation) Act, 1951 and Essential Commodities Act, 1955.
iii) Whether the Act and notifications violated fundamental rights under Articles 14, 19(1)(c), (f), (g), and 31.
iv) Whether the Act contravened Article 301, which ensures free trade and commerce throughout India.
v) Whether the power of repeal under Article 254(2) could be delegated to executive authorities.

F) PETITIONER/ APPELLANT’S ARGUMENTS

i) The counsels for Petitioners / Appellants submitted that:

• The Act trespassed into Parliament’s exclusive domain under Entry 52, List I, covering sugar industry regulation.

• It infringed Article 14, as the Cane Commissioner had wide discretionary powers to assign zones arbitrarily.

• Compelling cane farmers to trade only via co-operative societies violated Article 19(1)(c), since it indirectly imposed a forced association.

• It curtailed freedom to trade under Article 19(1)(g) and property rights under Article 31, without sufficient legal safeguards.

• The Act violated Article 301, by placing restrictions on inter-State commerce.

• They also argued the Act was repugnant to central legislation, particularly the Essential Commodities Act, 1955 and Sugarcane Control Orders, and thus void under Article 254(1).

G) RESPONDENT’S ARGUMENTS

i) The counsels for Respondents submitted that:

• The U.P. Legislature acted within its competence under Entry 33 of List III, especially post the Third Amendment.

• The impugned Act regulated sugarcane supply, not sugar production, and hence fell outside Entry 52, List I.

• There was no repugnancy, as Central and State laws occupied separate fields and served complementary purposes.

• The restrictions were reasonable and justifiable under Article 19(6) and were not arbitrary under Article 14.

• Article 301 was not violated, as reasonable restrictions in public interest are allowed by Article 304(b).

• They denied any delegation of repeal powers to the executive, arguing the notifications and orders were statutorily valid.

H) RELATED LEGAL PROVISIONS

i) Articles 14, 19(1)(c), (f), (g), 31, 301, 304(b), and 254 of the Constitution
ii) U.P. Sugarcane (Regulation of Supply and Purchase) Act, 1953
iii) Essential Commodities Act, 1955 – Sections 3 and 16
iv) Industries (Development and Regulation) Act, 1951 – Sections 18-G, 15, 16
v) Sugarcane Control Order, 1955 – Clause 7(1)

I) JUDGEMENT

a. RATIO DECIDENDI

i) The Court held that sugarcane was not covered under Entry 52, List I, since it was not a finished product of the sugar industry but raw material, which is governed under Entry 33, List III.
ii) There was no repugnancy under Article 254, as the Central and State legislations occupied distinct fields and dealt with different aspects of sugarcane regulation.
iii) The restrictions imposed under the Act were reasonable, aimed at protecting farmers and ensuring equitable distribution through co-operative societies.
iv) The Act did not infringe Articles 14, 19, or 31, as adequate safeguards and appeal mechanisms existed.
v) The power of repeal under Article 254(2) must be exercised by Parliament, and cannot be delegated to the executive, as attempted via Clause 7 of the Control Order.

b. OBITER DICTA 

i) The Court observed that mere possibility of repugnancy does not invalidate a law; it must be shown as a fact.
ii) It highlighted the delicate balance of federalism, urging that State autonomy in agricultural regulation must not be unnecessarily curtailed.

c. GUIDELINES 

• Central and State Legislatures can both legislate under Entry 33, List III, but if there is repugnancy, Central law prevails unless State law has Presidential assent.

• The scope of Article 254 applies only when both laws cover the same subject matter and conflict arises.

• The negative aspect of fundamental rights (e.g., the right not to associate) is not a fundamental right.

• Administrative discretion must be subject to appeals and judicial review to pass the Article 14 test.

J) CONCLUSION & COMMENTS

This landmark case reinforced the federal balance envisioned in the Indian Constitution. The Supreme Court clarified the scope of concurrent powers, especially in sectors involving agricultural commodities linked to industry. By rejecting a broad interpretation of Entry 52 (List I), the Court shielded States’ autonomy over primary agricultural regulation. It adopted a harmonious construction of the Constitution, emphasizing that repugnancy must be factual, not hypothetical. The decision remains pivotal in delineating legislative competence, doctrine of repugnancy, and reasonableness of restrictions on fundamental rights. It continues to be a significant authority on State powers in the regulation of agricultural produce vis-à-vis industrial usage.

K) REFERENCES

a. Important Cases Referred
i. Zaverbhai Amaidas v. State of Bombay, (1955) 1 SCR 799
ii. Commonwealth of Australia v. Bank of New South Wales, (1950) AC 235
iii. Clyde Engineering Co. Ltd. v. Cowburn, (1926) 37 CLR 466
iv. Shri Shambhu Nath v. State of Bihar, AIR 1950 SC 375
v. G.P. Stewart v. B.K. Roy Chaudhury, AIR 1939 Cal 628

b. Important Statutes Referred
i. Constitution of India, Articles 14, 19, 31, 301, 304, 254
ii. U.P. Sugarcane (Regulation of Supply and Purchase) Act, 1953
iii. Essential Commodities Act, 1955
iv. Industries (Development and Regulation) Act, 1951
v. Sugarcane Control Order, 1955