The age old principle enshrined in the Latin maxim expressio unius est exclusio alterius i.e. if a statute provides for a thing to be done in a particular manner then it has to be done in that manner and in no other manner and following any other course is not permissible, is squarely attracted. The principle was recently reiterated by the Supreme Court in Selvi J. Jayalalithaa v. State of Karnataka (2014) 2 SCC 401 and in Mackinon Mackenzie and Company Ltd. v. Mackinnon Employees Union (2015) 4 SCC 544. In the latter, it was further held that if the procedure prescribed is not followed, then such act of the authority has to be held to be null and void ab initio in law. The principle was yet again reiterated in Zuari Cement Ltd. v. Regional Director E.S.I.C. Hyderabad (2015) 7 SCC 690.
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