Enrolment fee rule-making upheld under the Advocates Act as within statutory authority and not ultra vires.

The Advocates Act, 1961 was read to permit payment and regulation of enrolment fees on admission to the State roll, with Section 24(1)(f) recognising enrolment fee, Section 28 allowing State Bar Council rules on admission conditions and instalments subject to Bar Council of India approval, and Section 49 conferring wider rule-making power on fees under the Act. Reading these provisions harmoniously with the Advocates' Welfare Fund Act, 2001, the enhanced enrolment fee was treated as within statutory authority and not shown to be unreasonable, unauthorized, or ultra vires. The challenge to the fee increase and supporting rules therefore failed.

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Issues: Whether the increase in enrolment fees and the related rule-making by the Bar Council of India and the State Bar Council was beyond statutory authority or otherwise invalid.

Analysis: The scheme of the Advocates Act, 1961 makes admission on the State roll subject to the Act and the rules made thereunder. Section 24(1)(f) expressly contemplates payment of enrolment fee, while Section 28 permits a State Bar Council to make rules as to the conditions for admission and instalments for payment of enrolment fee, subject to approval by the Bar Council of India. Section 49 confers a general rule-making power on the Bar Council of India, including the power to prescribe the fees which may be levied in respect of matters under the Act. The Court also noted the relevance of Section 15 of the Advocates' Welfare Fund Act, 2001. On a harmonious construction of the provisions, the prescribed enhancement in fee was treated as within the statutory framework and not shown to be unreasonable, unauthorized, or ultra vires.

Conclusion: The challenge to the enhanced enrolment fee and the supporting rules failed, and the objection was rejected.

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