Having considered the rival submissions, I have the following to say. The Parliament lays down the policy in more or less general terms and confers on an extraneous authority the power to make regulations or rules to carry out the legislative policy by implementing and administering the requirements of the parent Act within that framework. The doctrine of ultra vires envisages that an authority can exercise only so much power as is conferred on it by law. An action of the authority is intra vires when it falls within the limits of the power conferred on it but it is ultra vires if it is in conflict with the parent Act, is made without following the mandatory procedure prescribed by the parent Act or goes beyond the scope of authority conferred on the delegate. When a piece of subsidiary legislation is declared to be ultra vires, it is void and becomes unenforceable. As far as the ground No. 1 is concerned, a close reading of the EPOCA and section 103 in particular, does not reveal the procedures set by the Parliament but which were flawed by the 1st respondent in promulgating the impugned Regulations. The law did not categorise limits of power of the 1st respondent. I have considered the case of Council of Civil Service Union versus Minister for the Civil Service [1985] AC 374 HL cited by learned counsel for the applicants to support the existence of procedural impropriety. This case is distinguishable and inapplicable to the present matter particularly in view of the underlined words ‘this is because susceptibility to Judicial Review under this head

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