ITC Ltd. v. Agricultural Produce Market Committee

Quick Summary

The Supreme Court upheld the Tobacco Board Act made by Parliament under Entry 52 (List I). It said the Central law covers the field of tobacco growing, sale, and purchase. The State Market Committee’s fee on unprocessed tobacco conflicted with this. Because there was a collision, the Central Act prevailed, and the High Court decision was set aside.

Issues

• Is the Tobacco Board Act, made under Entry 52 of List I, within Parliament’s power?
• Can the Central Act and the State APMC Act run together for tobacco marketing?
• If there is a conflict, will the Central Act override the State law?

Rules

• Entry 52, Union List: Parliament can control an industry if it declares such control is in the public interest.
• Field Occupation & Conflict: When a Central law fully covers the field, a State law on the same subject cannot cut across it.
• Central Prevails on Repugnancy: If a Central and a State law collide in the same field, the Central law prevails (repugnancy principle).

Arguments

Judgment

Held: The Supreme Court upheld the Tobacco Board Act as a valid law under Entry 52 (List I). It found a direct conflict between the Central Act and the State APMC law in the same field.

Because of the conflict, the Central Act prevailed. The High Court judgment was set aside, and the APMC demand did not stand.

Ratio Decidendi

• Parliament’s control under Entry 52 covers tobacco industry and marketing as provided in the Tobacco Board Act.
• Where Central and State laws collide in the same field, the Central law prevails; both cannot operate together.

Why It Matters

The case shows how industry control by Parliament can displace State market levies when both target the same activity. It is a clean example of field occupation and repugnancy in action.

Key Takeaways

• Entry 52 lets Parliament control the tobacco industry by law.
• Tobacco Board Act occupies the field of growing, sale, and purchase of tobacco.
• Central over State when there is a direct conflict.

Mnemonic + 3-Step Hook

Mnemonic: “52 Takes the Lead.” — Entry 52 means Parliament leads in tobacco control.

1. Spot the field: tobacco growing, sale, purchase.
2. Check for clash: Central vs State rules on the same activity.
3. Apply the rule: Central Act prevails → State fee fails.

IRAC Outline

Glossary

Entry 52 (List I)

Parliament may control an industry in public interest by law.

Repugnancy

A conflict where Central and State laws cannot work together.

Occupies the Field

Central law fully covers a subject, leaving no room for State law.

APMC

State body that regulates agricultural markets and may levy fees.

FAQs

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