Administrative orders are not invalid merely for omitting the source provision if lawful power exists and the action is referable to it.

An administrative exemption order remains valid if the authority in fact possessed the underlying statutory power and the action is referable to a lawful source, even where the order does not expressly cite the correct provision. The SC held that the touring cinema exemption under Rule 14 was not liable to be set aside merely because Section 11 of the Tamil Nadu Cinemas (Regulation) Act was not mentioned, since the exemption power was traceable to the amended proviso in Rule 14 and that amendment had already been upheld. The appellate court's interference was therefore unwarranted and the exemption stood restored.

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Issues: Whether the Government's order granting exemption to a touring cinema under Rule 14 of the Tamil Nadu Cinemas (Regulations) Rules, 1957 was invalid merely because it did not expressly refer to Section 11 of the Tamil Nadu Cinemas (Regulation) Act, 1955.

Analysis: The exemption power was traceable to the proviso inserted in Rule 14 by Government Order No. 1326 dated 06-09-1995, and the legality of that amendment had already been upheld. An exercise of statutory power is not vitiated merely because the order does not cite the exact source provision, or refers to a wrong provision, so long as the power actually exists in law and the action can be traced to that source. The omission of an express reference to Section 11 therefore did not justify setting aside the exemption order.

Conclusion: The exemption order was valid and could not be quashed on the ground that Section 11 was not expressly mentioned.

Final Conclusion: The appellate court's interference was unwarranted, and the exemption in favour of the touring cinema stood restored.

Ratio Decidendi: An administrative order is not invalid merely because it omits or misstates the source of power, if the authority in fact possessed the power and the action is otherwise referable to a valid legal provision.

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