Emergency Proclamation validity turns on timely parliamentary approval, not Official Gazette publication of resolutions.

Parliamentary approval of a Proclamation of Emergency under article 352 was effective on timely passage by both Houses, even though the approving resolutions were not published in the Official Gazette. Official parliamentary records and debates were sufficient proof of such approval, and any delay in publication did not affect validity because the Constitution did not require gazette publication of the resolutions. On that basis, the Emergency Proclamations remained in force until revoked, the extension of the House of the People's duration was valid, and the Finance Act, 1976 could not be impugned on that ground.

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Issues: Whether the Proclamations of Emergency were validly issued and remained in force despite non-publication in the Official Gazette of the parliamentary resolutions approving them, and whether the House of the People (Extension of Duration) Act, 1976 and the Finance Act, 1976 were thereby valid.

Analysis: The constitutional scheme under article 352 required the Proclamation to be laid before each House and approved by resolutions of both Houses within the prescribed period, but it did not prescribe that the approving resolutions must themselves be published in the Official Gazette. The Court held that the resolutions were in fact passed by both Houses within time, and that their publication in the official parliamentary debates furnished adequate proof of their passage. Relying on the rules governing parliamentary proceedings and the Evidence Act provisions requiring judicial notice of such proceedings, the Court held that the parliamentary records were sufficient to establish approval of the Proclamations. It further held that delay, if any, in publishing those proceedings did not affect the validity of the resolutions, since the decisive fact was timely passage, not gazette publication.

Conclusion: The Proclamations of Emergency continued in force until revoked in 1977, and the extension of the House of the People's duration was valid; consequently, the Finance Act, 1976 could not be challenged on that ground.

Ratio Decidendi: Where the Constitution does not require publication in the Official Gazette, parliamentary resolutions approving a Proclamation of Emergency are effective upon due passage within the constitutional time limit, and official parliamentary records are sufficient proof of such approval.

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