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[1961].S.C.R. 957.

(2) A.I.R. (1956) S.C. 60.

(4) [1962] Supp. I.S.R. 405.

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Same was the position in Ameer-un-nissa's case and the case of the Director of Endowments," Govt. of Hyderabad (2) where this court had to deal with the effect of Firmans issued by the Nizam who was at the time an absolute Ruler.' It was held that such Firmans had the effect of law because in,, all domestic matters, the Nizam issued Firmans to determine the rights of his subjects." The Firmans were not based on consent, but derived their authority from the command of the Sovereign viz.,' the Nizam, expressing his sovereign will.:

For example, in Ameer-un-nissa's case, (1) the Firmam set aside the decision of a Special Commission in respect of certain claimants and though a subsequent Firman revoked the earlier Firman, it did not restore the decision of the Special 'Commission. It was in these circumstances that this court observed "The determination of all these questions depends primarily upon the meaning and effect to be gives to the various' 'Firmans" of the, Nizam which we have set out already. .'It cannot be disputed that prior to the integration of Hyderabad State with the Indian Union and the coming to force of the Indian Constitution, the Nizam of Hyderabad enjoyed uncontrolled sovereign powers. He was the supreme legislature, the supreme judiciary and the supreme head of the executive, and there were no constitutional limitations upon his authority to act in any of these capacities. The 'Firmans' were: expressions of the sovereign will of the Nizam and they were binding in the same way as any other law;...nay, they would. Override all other laws which were in conflict. with them. So long as' a particular 'Firman' 'held the field" that alone would govern or regulate the. fights of the parties concerned, though it could 'be annulled or (1) A.I.R. (1955) S.C. 352,(2) A.I.R. (1956) S. 60;
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modified by a later 'Firman' at any time that the Nizam willed."

These observations do not support the extreme view that any, and every order of a sovereign Ruler is law. In Promod Chandra Deb's case (1). the Khorposh grants were considered. in the context of the rules laid down in Order 31 of the Rules, Regulations and Privileges of Kha jnadars which were. accepted by the Ruler of the State is the law governing the rights of Khorposhdars. It was in these circumstances held that the rules continued in force till they were changed; by a competent; authority, and the grants made in accordance with those rules continued to be valid.