Prospective operation of amended price control order bars enhanced levy on sales completed before the amendment.

An amending rice price control order operated prospectively because the governing order contained no express retrospective language or necessary implication. The Court held that a notification or amendment normally takes effect from the date of issue and does not reopen completed transactions; the price payable under the levy arrangement was therefore the controlled price prevailing on the date of sale, when property in the goods passed. As the later amendment was neither explanatory nor declaratory, the enhanced price could not be applied to supplies made before the amendment came into force, and the claim for the difference was rightly rejected.

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Issues: Whether the enhanced price fixed by the amended rice price control order applied to supplies made before the amendment came into force.

Analysis: The governing order contained no deeming or other language indicating retrospective effect. In the absence of express words or necessary implication, a notification or amending order operates from the date it is issued and does not reopen transactions already completed. The price payable under the levy arrangement was the controlled price prevailing on the date of sale, because the property in the goods passed when the supplies were made. The later amendment was neither explanatory nor declaratory, and the principle against retrospectivity applied with full force.

Conclusion: The enhanced price was not payable for supplies made before the amending order came into force, and the claim for the difference was rightly rejected.

Ratio Decidendi: In the absence of express retrospective language or necessary implication, an amending price control order operates prospectively and does not alter the rights or liabilities arising from sales already completed.

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