Administrative instructions may supplement statutory rules when consistent with the parent scheme; challenge to vires failed.

Administrative instructions issued under an enabling rule may validly regulate incidental or supplementary procedure if they remain consistent with the parent Act and rules. Here, the instruction only governed the procedure for first stage and second stage dealers and did not amend, supersede, or contradict the statutory scheme. Deletion of the earlier provision did not by itself extinguish the power to issue a consistent supplementary instruction. The challenge to vires therefore failed, and the instruction was upheld as valid within the rule-making framework.

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Issues: Whether the impugned administrative instruction could be sustained after deletion of the earlier rule and whether such instruction was within the power conferred by the relevant rule.

Analysis: Rule 31 empowered the Board, Chief Commissioner, or Commissioner to issue written instructions on incidental or supplemental matters, provided they remained consistent with the Act and the rules. The instruction in question only regulated the procedure to be followed by first stage and second stage dealers and did not amend, supersede, or run counter to the statutory scheme. The governing principle is that administrative instructions may supplement statutory rules but cannot supplant them. The deletion of the earlier provision did not, by itself, disable the authority from issuing a consistent supplementary instruction under the enabling rule.

Conclusion: The administrative instruction was validly issued under the enabling rule and the challenge to its vires failed.

Final Conclusion: The writ petition was rejected, and the impugned administrative instruction was upheld as being consistent with the statutory framework.

Ratio Decidendi: Administrative instructions may validly supplement statutory rules when issued under enabling power, but they cannot amend, supersede, or contradict the rules or the parent enactment.

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