Publication by Gazette notice and inspection availability can satisfy planning law requirements; minor defects may be cured by a validating clause.

The SC held that publication of an approved Outline Development Plan and Zonal Regulations can be satisfied by a Gazette notice stating that the instrument is available for inspection, when the Act and Rules are read harmoniously as a single publication-and-inspection scheme. The regulations were treated as part of the integrated planning instrument, not as a separate document requiring detached publication. The Court further noted that any non-prejudicial defect in the mode of publication was protected by the validating clause, which cured mere omission, defect or irregularity where the public purpose had been served. The challenge to the licences and approval process therefore failed.

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Issues: Whether publication of the approved Outline Development Plan and Zonal Regulations by a Gazette notice stating that the plan was available for inspection satisfied the statutory requirement of publication, and whether any defect in publication was cured by the validating provision.

Analysis: The statutory scheme required the approved plan and regulations to be published in the prescribed manner, read with the rules governing publication and the requirement that the plan be displayed and kept available for inspection. On a harmonious construction of the Act and the Rules, the Gazette notice informing the public that the approved plan was available for inspection was treated as sufficient compliance with the publication requirement. The regulations were not to be viewed as severed from the plan, but as part of the same integrated scheme. In any event, any defect in the mode of publication, having served its purpose and not affecting the merits, fell within the validating clause which protected acts and proceedings from challenge on the ground of mere omission, defect or irregularity.

Conclusion: The publication requirement was substantially complied with and any defect stood cured; the challenge to the licences and the approval process therefore failed.

Ratio Decidendi: Where a statute and its rules prescribe publication of an approved planning instrument in a manner intended to notify the public and permit inspection, a Gazette notice conveying that the instrument is available for inspection may satisfy the requirement if read with the statutory scheme, and any non-prejudicial defect in publication is capable of being validated by a saving clause.

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