Citizenship registration cancellation requires proof of fraud or concealment; general revocation powers cannot expand a special statute.

Cancellation of citizenship registration was invalid because deprivation under the Citizenship Act could be exercised only on proof of fraud, false representation, or concealment of a material fact, and that ground was not established on the record. The applicants had disclosed that earlier attempts to secure permission to settle permanently in India had been rejected, so suppression was not proved. Section 21 of the General Clauses Act could not be used to enlarge the Collector's power where the special citizenship statute created a limited scheme for registration and deprivation. The cancellation orders and the direction to leave India were set aside, with costs awarded.

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Issues: (i) whether the cancellation of the petitioners' registration as citizens of India was valid under Section 10(2)(a) of the Citizenship Act, 1955; (ii) whether the Collector could cancel the registration by relying on Section 21 of the General Clauses Act, 1897.

Issue (i): whether the cancellation of the petitioners' registration as citizens of India was valid under Section 10(2)(a) of the Citizenship Act, 1955.

Analysis: The power to deprive a citizen of citizenship under Section 10(2)(a) of the Citizenship Act, 1955 could be exercised only where registration had been obtained by fraud, false representation, or concealment of a material fact. The record showed that the petitioners had disclosed in their registration applications that their earlier attempts to obtain permission to settle permanently in India had been rejected. The alleged suppression was therefore not established.

Conclusion: The cancellation was invalid and was not sustainable under Section 10(2)(a) of the Citizenship Act, 1955.

Issue (ii): whether the Collector could cancel the registration by relying on Section 21 of the General Clauses Act, 1897.

Analysis: Section 21 of the General Clauses Act, 1897 does not confer an unrestricted power to revoke an order in a situation where the special statute creates a distinct and limited scheme for registration and deprivation of citizenship. The power exercised by the Collector was not one that could be justified under that provision.

Conclusion: The Collector had no authority under Section 21 of the General Clauses Act, 1897 to cancel the registration certificates.

Final Conclusion: The orders cancelling the petitioners' registration as citizens and directing them to leave India were illegal and were set aside, with costs awarded to the petitioners.

Ratio Decidendi: Where a statute permits deprivation of citizenship only on proof of fraud, false representation, or concealment of a material fact, the authority cannot cancel registration unless that ground is established, and a general saving provision cannot enlarge a special statutory power of deprivation.

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