Special law prevails over municipal licensing: registered architects cannot be subjected to separate corporation conditions for building plans.

The Architects Act, 1972 operates as a special and complete code governing qualification, registration and the use of the designation "architect", so a municipal corporation cannot continue to apply a separate licensing regime to registered architects under the Delhi Municipal Corporation Act, 1957 and the Building Bye-laws, 1959. The corporation's general and residuary bye-law-making powers could support regulation only for persons not covered by the special law, and section 502 of the municipal statute prevented its provisions from being read so as to override an existing law. As a result, registered architects were not required to comply with the impugned municipal licence, fee or security deposit conditions to submit building plans.

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Issues: Whether the Delhi Municipal Corporation could, after the coming into force of the Architects Act, 1972, continue to regulate the practice of registered architects by insisting on Corporation-issued licences, fees, security deposits and allied conditions under the Delhi Municipal Corporation Act, 1957 and the Building Bye-laws, 1959.

Analysis: The Corporation's power to frame licensing provisions was traced to the general scheme of the Delhi Municipal Corporation Act, 1957, including the residuary bye-law-making power. That power could at best support regulatory measures for persons not covered by the special law. The Architects Act, 1972 was treated as a complete special enactment governing qualification, registration and the use of the designation "architect", and section 502 of the Delhi Municipal Corporation Act, 1957 prevented the general municipal law from being construed so as to disregard a law already in force. On that basis, the municipal provisions and bye-laws could not continue to operate against persons registered as architects under the Architects Act, 1972.

Conclusion: The Corporation had no authority to impose its licensing regime on registered architects, and the impugned municipal actions could not affect their status or practice as architects or their entitlement to submit building plans without complying with those conditions.

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