Money Bill certification and retrospective tenure extension sustained, validating the Lokayukta's continued holding of office.

Speaker certification of a Bill as a Money Bill is treated as final under Article 199(3), and Article 212 bars judicial scrutiny of legislative procedure on the ground of irregularity. On that basis, the challenge to the Uttar Pradesh Lokayukta and Up-Lokayuktas (Amendment) Act, 2012 failed, and the enactment was upheld after Governor's assent. The retrospective deeming provision extending the Lokayukta's term from six to eight years was given full effect, so the incumbent's continuance in office was held to be under valid authority of law and the quo warranto challenge could not succeed.

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Issues: (i) Whether the Uttar Pradesh Lokayukta and Up-Lokayuktas (Amendment) Act, 2012 was invalid on the ground that it was enacted as a Money Bill and that the legislative procedure was unconstitutional; (ii) Whether the respondent continued to hold the office of Lokayukta validly after the expiry of the original six-year term under the amended statute.

Issue (i): Whether the Uttar Pradesh Lokayukta and Up-Lokayuktas (Amendment) Act, 2012 was invalid on the ground that it was enacted as a Money Bill and that the legislative procedure was unconstitutional.

Analysis: The constitutional scheme governing Money Bills and State legislative procedure leaves the Speaker's certification of a Bill as a Money Bill final under Article 199(3), while Article 212 bars judicial inquiry into legislative proceedings on the ground of procedural irregularity. The Court further held that, once the Governor's assent was obtained, the resulting enactment could not be invalidated merely because the petitioner questioned the manner in which the Bill was processed. The challenge based on Articles 197, 198, 199 and 200 was therefore rejected, and the retrospective deeming provision in the amendment was treated as a valid exercise of legislative power.

Conclusion: The Amendment Act was upheld as valid and the challenge to its enactment failed.

Issue (ii): Whether the respondent continued to hold the office of Lokayukta validly after the expiry of the original six-year term under the amended statute.

Analysis: The amended Section 5 substituted a term of eight years and made the amendment applicable to the sitting Lokayukta. The Court held that the deeming clause must be given full effect and that the extension of tenure was a matter of legislative policy, not something to be narrowed as a measure enacted merely for one individual. In view of the valid amendment, the respondent's continuance in office was under the authority of law and the quo warranto challenge could not succeed.

Conclusion: The respondent was validly holding office as Lokayukta under the amended Act.

Final Conclusion: The writ petitions failed, the appeal and transfer case were disposed of on the basis that the amendment was valid, and the respondent's continuance in office stood affirmed while the State was directed to make a fresh selection expeditiously.

Ratio Decidendi: A Bill certified as a Money Bill by the Speaker is not open to judicial reappraisal on procedural grounds, and a validly enacted retrospective amendment extending tenure governs the incumbent's continuance in office.

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