Electricity tariff revision under amended licensing law upheld; pre-existing licence did not bar unilateral charge enhancement.

After the 1956 amendment to the Electricity (Supply) Act, 1948, a pre-existing licensee could revise electricity charges under sections 57 and 57A read with the Sixth Schedule without a fresh rating committee fixing the tariff. The amended scheme was treated as incorporating the Sixth Schedule into earlier licences and as regulating the procedure for future revisions, not as extinguishing any vested right to continue earlier rates. The earlier licence terms and prior statutory procedure yielded to the extent of inconsistency with the amended provisions, and consumers had no enforceable right to insist on continuation of the 1952 rates until a new committee acted.

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Issues: Whether, after the amendment of the Electricity (Supply) Act, 1948 in 1956, a licensee whose licence pre-dated the amendment could unilaterally enhance electricity charges in accordance with section 57A and the Sixth Schedule, without a fresh rating committee fixing the charges.

Analysis: The statutory scheme before the amendment required charges fixed by the Government on the recommendation of a rating committee to continue until altered through that procedure. After the amendment, section 57 and section 57A incorporated the Sixth Schedule into pre-existing licences and gave the licensee a statutory right to adjust charges subject to the safeguards in that Schedule. The change was held to regulate future conduct and procedure, not to destroy any vested right, because the controversy concerned the method of revising charges rather than a fixed substantive entitlement to a particular tariff. The earlier licence terms and the prior statutory scheme were treated as displaced to the extent of inconsistency with the amended provisions.

Conclusion: The licensee was competent to enhance the charges unilaterally in accordance with the amended statutory scheme, and the appellants had no enforceable vested right to insist on continuation of the 1952 rates until a fresh rating committee acted.

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