Constitutional extension of a central statute can override inconsistent local rules through implied repeal and sustain conviction.

Article 371F(n) was treated as sufficient constitutional authority to extend the Arms Act, 1959 to Sikkim even though the Sikkim Arms Rules, 1962 had not been expressly repealed. The extended central enactment operated by force of the Constitution and displaced the local rules to the extent of inconsistency through implied repeal. On that basis, the Arms Act was regarded as validly in force in Sikkim, and a conviction founded on a plea of guilty was not open to challenge on merits on this ground.

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Issues: Whether the Arms Act, 1959 was validly extended to Sikkim under Article 371F(n) of the Constitution of India despite the continued existence of the Sikkim Arms Rules, 1962, and whether the conviction based on a plea of guilty could be maintained.

Analysis: The appeal depended on whether the extended central enactment operated in Sikkim notwithstanding the non-repeal of the corresponding local rules. The reasoning applied the principle that extension of a law into a new does not fail merely because an earlier corresponding law remains in force, since the later law may override the earlier law by necessary implication. Article 371F contains a non obstante clause and expressly empowers the President to extend any existing enactment to Sikkim. On that basis, the extended Arms Act derived force from the Constitution itself and was effective even though the Sikkim Arms Rules, 1962 had not been expressly repealed. The continued operation of the local rules was held to be displaced by implied repeal upon extension of the central law. Since the Arms Act was validly in force, the plea of guilty attracted the bar against challenging the conviction on merits.

Conclusion: The Arms Act, 1959 was validly extended and enforced in Sikkim, the corresponding Sikkim Arms Rules, 1962 stood impliedly repealed, and the conviction was not open to challenge on this ground.

Final Conclusion: The appeal failed because the statutory basis of conviction was upheld and the local law was held to have been overridden by the constitutional extension of the central enactment.

Ratio Decidendi: Where the Constitution expressly authorises extension of an enactment to a State with a non obstante clause, the extended law takes effect notwithstanding an existing corresponding local law and may impliedly repeal that law to the extent of inconsistency.

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