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Issues: Whether the Commission had power under section 36D of the Monopolies and Restrictive Trade Practices Act, 1969, to direct that any future advertisement issued by the appellant must be approved by the Commission in advance.
Analysis: The power conferred by the unamended provision enabled the Commission, after inquiry, to direct discontinuance or non-repetition of the unfair trade practice and to grant related reliefs connected with the practice under inquiry. The amended language permitting disclosure, issue or publication of information, statements or advertisements relating to such practice could not be stretched to authorise a continuing supervisory control over all future advertisements. The Act already equipped the Commission to act against breach of cease and desist orders, and the impugned direction went beyond the statutory scheme.
Conclusion: The Commission had no power to impose a blanket prior-approval requirement for future advertisements, and the impugned direction was invalid.
Ratio Decidendi: A regulatory authority cannot impose a continuing prior-approval condition for all future conduct unless such supervisory power is expressly conferred by the governing statute.