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Issues Involved:
1. Legislative Competence and Vires of the Amending Act 2. Promissory Estoppel 3. Classification and Tariff Rates 4. Validity of Revised Tariff and Billing Summary: 1. Legislative Competence and Vires of the Amending Act: The appellants challenged the Karnataka Electricity (Supply) (Karnataka Amendment) Act, 1981, arguing it was ultra vires due to legislative incompetence and repugnancy with Central laws. The High Court upheld the Act, referencing Entries 52 and 54 of List I, and Entries 26 and 27 of List II, concluding that the State Legislature had the competence to enact the amendment. The Court relied on precedents such as *Tika Ramji v. State of U.P.*, *State of Uttar Pradesh & others v. Synthetics and Chemical Limited and others*, and *Hoechst Pharmaceuticals Ltd. v. State of Bihar & Ors.*, emphasizing that the amendment did not conflict with Central legislation and was valid under Article 254(2) of the Constitution. 2. Promissory Estoppel: The appellants argued that the principle of promissory estoppel should prevent the Karnataka Electricity Board from revising tariffs contrary to the 1976 agreement. The High Court rejected this, noting that promissory estoppel cannot be invoked against statutory provisions. The Court cited *Excise Commissioner, U.P. v. Ram Kumar* and *Union of India v. Godfrey Philips India Ltd.*, concluding that the statutory power under Section 49(5) of the Electricity (Supply) Act overrides any agreement. 3. Classification and Tariff Rates: The appellants contended that the smelter plant should not be classified with other power-intensive industries due to its unique electricity requirements. The High Court held that broader classification based on power intensity was reasonable and not arbitrary, as the smelter plant was categorized under HT-IA since 1978 without any protest from the appellants. The Court found no violation of Article 14, stating that uniform tariff rates were justified under the amended Section 49. 4. Validity of Revised Tariff and Billing: The appellants challenged the revised tariffs and supplementary bills issued by the Board. The High Court, noting the Board's willingness to correct any errors in billing, dismissed the claim. The Court emphasized that the revised tariffs were in accordance with the statutory provisions and applicable uniformly to all consumers in the same category. Conclusion: The Supreme Court, endorsing the High Court's reasoning, upheld the vires of the Karnataka Amendment Act, dismissed the applicability of promissory estoppel, validated the classification and uniform tariff rates, and found no merit in the challenge to the revised tariffs and billing. The appeal was dismissed, with no order as to costs. The Court also suggested a pragmatic approach by the Central and State Governments to balance the interests of the electricity boards and the aluminium industry.
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