Retrospective validating legislation can neutralise earlier writ relief once the legal basis of invalidation has disappeared.

A retrospective validating enactment may remove the legal basis of an earlier judicial invalidation where the legislature has competence, and the prior relief then loses its operative force. Applied here, earlier writ decisions could not continue to bind the State after the Supreme Court reversed the connected matter and upheld the constitutional validity of the Entry Tax Act, 1979; section 3 of the Repealing Act, 1981 was construed as continuing or re-enacting that Act retrospectively and neutralising the earlier mandamus against enforcement.

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Issues: (i) Whether the earlier writ decisions in favour of the petitioners continued to bind the State despite the Supreme Court's later reversal in the connected matter. (ii) Whether section 3 of the Repealing Act, 1981 validly revived and continued the Entry Tax Act, 1979 and made the earlier mandamus ineffective.

Issue (i): Whether the earlier writ decisions in favour of the petitioners continued to bind the State despite the Supreme Court's later reversal in the connected matter.

Analysis: The earlier High Court judgment was substantially declaratory and its basis was altered when the Supreme Court upheld the constitutional validity of the Entry Tax Act, 1979. Once the foundational invalidity found by the High Court ceased to exist, the State could not be treated as perpetually bound to disregard the subsequently declared law merely because no separate appeal had been filed in every connected writ petition.

Conclusion: The earlier writ decisions did not continue to confer an enforceable bar against the State after the Supreme Court's reversal.

Issue (ii): Whether section 3 of the Repealing Act, 1981 validly revived and continued the Entry Tax Act, 1979 and made the earlier mandamus ineffective.

Analysis: A validating enactment is effective when the legislature has competence and retrospectively removes the defect or changes the legal basis on which the judicial invalidation rested. Here, the Supreme Court had already removed the very infirmities found by the High Court. Section 3 was therefore construed as re-enacting the Entry Tax Act, 1979 with retrospective effect and neutralising the earlier mandamus issued against enforcement of that Act.

Conclusion: Section 3 validly continued the Entry Tax Act, 1979 and rendered the earlier mandamus ineffective.

Final Conclusion: The appeals failed because the validating legislation, read with the Supreme Court's prior reversal, removed the foundation of the earlier High Court relief and left the tax law operative against the petitioners.

Ratio Decidendi: A legislature competent in the field may, by retrospective validating enactment, remove the legal basis of an earlier judicial invalidation and thereby render the prior decision ineffective; where the earlier basis has already been erased by a superior court's reversal, the validating provision may be treated as a lawful re-enactment of the statute.

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