Regulation-making power under the Electricity (Supply) Act upheld for employee discipline, termination and service control.

The Supreme Court held that the Board's residuary regulation-making power under the Electricity (Supply) Act, 1948 covered service matters arising from its functions. Section 79(c) was treated as limited to duties, salaries, allowances and other service conditions, while Section 79(k) was read more broadly. Reading Section 15 with Section 79(k), the power to appoint employees was held to include, by necessary implication, power to regulate disciplinary control and termination of service. The regulation governing appointment, discipline and termination was therefore within the Board's competence, and the challenge to its validity failed.

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Issues: Whether the Board had power under the Electricity (Supply) Act, 1948 to frame regulations governing appointment, disciplinary control and termination of its employees.

Analysis: Section 79(k) was treated as a residuary regulation-making power covering matters arising out of the Board's functions, while Section 79(c) was held to be narrower and confined to duties, salaries, allowances and other service conditions. Reading Section 15 with Section 79(k), the power to appoint employees was held to carry by necessary implication the power to regulate disciplinary action and termination of service. The regulation was therefore upheld as within the Board's competence, and the High Court's contrary view was rejected.

Conclusion: The regulation was valid and the Board was competent to make it; the challenge to its vires failed.

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