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Issues: (i) Whether the amended Rice Milling Industry (Regulation) Act, 1958 validly brought rice hullers within its sweep and whether the relevant definitions covered their operations; (ii) Whether the licensing and permit provisions in Sections 5 and 6 imposed an unreasonable restriction or conferred unguided and uncanalised power violating Articles 14 and 19; (iii) Whether the classification between rice millers and rice hullers was discriminatory.
Issue (i): Whether the amended Rice Milling Industry (Regulation) Act, 1958 validly brought rice hullers within its sweep and whether the relevant definitions covered their operations.
Analysis: The amended definition of "milling rice" was read in the setting of the statute and its object of regulating rice milling, protecting the hand-pounding industry, and improving quality and distribution. The Court held that the processes carried on by rice hullers fell within the expanded meaning of milling rice and polishing rice. Section 3A was treated as reinforcing, rather than limiting, that interpretation.
Conclusion: The amended Act validly covered rice hullers and their operations were within its scope.
Issue (ii): Whether the licensing and permit provisions in Sections 5 and 6 imposed an unreasonable restriction or conferred unguided and uncanalised power violating Articles 14 and 19.
Analysis: Sections 5 and 6 were held to be regulatory in character and supported by detailed statutory guidelines, including factors for grant of permits, preference norms, and appellate supervision. The licensing officer had no discretion to refuse a licence once the statutory conditions were met, and the scheme was aimed at public interest control of the industry.
Conclusion: The provisions did not impose an unreasonable restriction and did not suffer from the vice of uncanalised or unguided power.
Issue (iii): Whether the classification between rice millers and rice hullers was discriminatory.
Analysis: The Court found that rice millers and rice hullers constituted a rational class for regulatory purposes because both used power-driven processes and had a substantial functional overlap. The classification had an intelligible differentia and a direct relation to the statutory objectives of protecting the indigenous hand-pounding industry, improving rice quality, and ensuring distribution.
Conclusion: The classification was valid and did not offend Article 14.
Final Conclusion: The constitutional challenges failed, and the impugned writ petitions were dismissed with costs in the principal batch and without costs in the remaining batch.
Ratio Decidendi: A regulatory licensing scheme founded on statutory guidelines and directed to public interest objectives is constitutionally valid where the classification is reasonable and the authority is not vested with arbitrary discretion.