Continuity of mining regulations and director liability under the Mines Act upheld on statutory construction and saving provisions.

Subordinate regulations made under the Mines Act, 1923 retained their character as delegated legislation and, on repeal and re-enactment, continued in force under the general saving rule in section 24 of the General Clauses Act so far as they were not inconsistent with the Mines Act, 1952; the 1926 Coal Mines Regulations were therefore operative and prosecutions based on them were competent. The phrase "any one of the directors" in section 76 of the 1952 Act was construed in light of the statutory scheme to permit prosecution of every director of the owning company, so the Article 14 challenge failed. Directors of managing agents were held not liable because they were neither owners, agents nor managers under the Act.

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Issues: (i) Whether the Coal Mines Regulations, 1926 survived the repeal of the Mines Act, 1923 and continued in force under section 24 of the General Clauses Act, 1897. (ii) Whether the expression "any one of the directors" in section 76 of the Mines Act, 1952 means one director only or every director, and whether prosecution of all directors is invalid under Article 14 of the Constitution of India.

Issue (i): Whether the Coal Mines Regulations, 1926 survived the repeal of the Mines Act, 1923 and continued in force under section 24 of the General Clauses Act, 1897.

Analysis: Regulations made under section 29 of the Mines Act, 1923 were subordinate legislation notwithstanding the statutory form that they were to have effect as if enacted in the Act. That deeming language preserved their status for construction and validity, but did not merge them into the parent Act for all purposes. On repeal and re-enactment of the Act, section 24 of the General Clauses Act operated to continue existing rules and regulations, so far as they were not inconsistent with the re-enacted provisions, until superseded by fresh regulations. The Court therefore held that the 1926 Regulations were still operative at the relevant time and were to be treated as regulations made under the Mines Act, 1952.

Conclusion: The survival of the 1926 Regulations was upheld and the prosecutions based on them were competent.

Issue (ii): Whether the expression "any one of the directors" in section 76 of the Mines Act, 1952 means one director only or every director, and whether prosecution of all directors is invalid under Article 14 of the Constitution of India.

Analysis: The phrase "any one" is capable, depending on context, of meaning either one only or every one. Reading section 76 with the scheme and object of the Mines Act, the Court concluded that Parliament intended to place the directors of a public company in the same position as an individual owner for purposes of liability, so that all directors could be prosecuted and punished. Because that construction was adopted, no question of hostile discrimination or arbitrariness under Article 14 arose. The Court also held that the managing agents were neither owners nor agents nor managers within the Act, so no prosecution could lie against their directors.

Conclusion: The words "any one of the directors" were held to mean every one of the directors, and the Article 14 challenge failed; the managing agents' directors were not liable.

Final Conclusion: The Court sustained the continuity and enforceability of the 1926 mining regulations, upheld prosecution of all directors of the owning company, and rejected liability of the managing agents' directors, resulting in a mixed outcome across the connected appeals.

Ratio Decidendi: Subordinate rules and regulations that are treated as if enacted in a parent Act do not lose their character as subordinate legislation and, on repeal and re-enactment of the parent Act, continue in force under the general saving provision unless the later statute otherwise provides; statutory words such as "any one" must be construed in light of the legislative scheme and object.

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