Which one of the following is 1st leading case decided by Supreme Court on delegated legislation after the Constitution came into force ?

Re-Delhi Laws Act, 1912
Jatindra Nath Gupta V. Province of Bihar
Kathi Raning Rawat V. State of Saurashtra
Raj Narayan Singh V. Patna Administration Committee

The correct answer is (b) Jatindra Nath Gupta V. Province of Bihar.

The case was decided in 1952, and it was the first leading case decided by the Supreme Court on delegated legislation after the Constitution came into force. The case concerned the validity of a rule made by the Government of Bihar under the Bihar General Clauses Act, 1899. The rule provided that any person who was convicted of an offence under the Bihar Excise Act, 1915, would be liable to be punished with imprisonment for a term not exceeding three years.

The petitioner in the case, Jatindra Nath Gupta, had been convicted of an offence under the Bihar Excise Act, and he was sentenced to imprisonment for a term of two years. He challenged the validity of the rule on the ground that it was ultra vires the Bihar General Clauses Act.

The Supreme Court held that the rule was valid. The Court held that the Bihar General Clauses Act gave the Government of Bihar the power to make rules for carrying into effect the provisions of the Bihar Excise Act. The Court further held that the rule was a reasonable exercise of the power conferred by the Bihar General Clauses Act.

The decision in Jatindra Nath Gupta V. Province of Bihar is an important landmark in the development of the law of delegated legislation in India. The decision clarifies the scope of the power of the executive to make delegated legislation, and it sets out the principles that the courts will apply in determining the validity of delegated legislation.

The other options are incorrect because they are not leading cases decided by the Supreme Court on delegated legislation after the Constitution came into force.

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