Special law on architectural education prevails over general technical education law, preserving Council of Architecture control.

The Architects Act, 1972 is the special and self-contained statute governing architectural education, recognised qualifications, registration, and minimum standards, and it vests regulatory control in the Council of Architecture. The All India Council for Technical Education Act, 1987 is a broader enactment for technical education generally and does not displace the specialist statutory regime for architecture. Applying the principles of implied repeal and generalia specialibus non derogant, the two enactments are capable of harmonious construction and there is no clear legislative intent to abolish the Council of Architecture's authority. The Architects Act therefore prevails on architectural standards and intake capacity.

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Issues: Whether the All India Council for Technical Education Act, 1987 impliedly repeals the Architects Act, 1972 in relation to architectural education and the fixation of norms, standards, and intake capacity of architectural institutions.

Analysis: The Architects Act, 1972 is a self-contained code dealing specifically with architectural education, recognised qualifications, registration of architects, and the prescription and maintenance of minimum standards. It contains an overriding non obstante clause and vests the relevant regulatory functions in the Council of Architecture. By contrast, the All India Council for Technical Education Act, 1987 is a wider enactment covering several branches of technical education, of which architecture is only one component, and its role in relation to pre-existing specialist bodies is not intended to displace their statutory authority. The doctrine of implied repeal is applied only where the two enactments are irreconcilable, and the rule generalia specialibus non derogant requires the special law to prevail over the general law unless a contrary legislative intent is clearly shown. The provisions of the two Acts can be read harmoniously, and there is no clear indication that Parliament intended to abolish or supersede the Council of Architecture's control over architectural standards.

Conclusion: The Architects Act, 1972 is the special law for architectural education and prevails over the All India Council for Technical Education Act, 1987 on that subject. The latter does not impliedly repeal the former, and the Council of Architecture remains the final authority for fixing standards and intake capacity of architectural institutions.

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