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Issues: Whether the State enactment acquiring the undertaking was beyond legislative competence or repugnant to the Central electricity laws, and whether it required Presidential assent.
Analysis: The core character of the impugned enactment was acquisition of an undertaking in public interest with provision for compensation, not regulation of electricity supply in the sense contemplated by the Central enactments. Applying the doctrine of pith and substance, the Court found that the State law operated in a different field from the Indian Electricity Act, 1910 and the Electricity (Supply) Act, 1948. The purchase and revocation provisions in the 1910 Act were held inapplicable because the appellants were not licensees. The provisions of the 1948 Act made applicable to generating companies did not convert them into licensees, and the specific machinery for purchase under that Act also did not govern the case. Since the State law and the Central laws did not occupy the same field and there was no direct conflict, repugnancy under Article 254 was not established.
Conclusion: The State enactment was within legislative competence and was not repugnant to the Central laws; Presidential assent was not required.