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Section 184: Provisions of Act not to apply in certain cases

Electricity Act • Official Statutory Text & Practice Guide

Statutory Regulation
Legal Standard
Competent Court / Tribunal
Act 2003
Section 183 All 185 Sections of Electricity Act Section 185

Legal Commentary & Landmark Judgments: Section 184

Section 184 of the Act exempts naval, military, and air force works, and other designated defense installations from the provisions of the Act, preserving sovereign defense energy autonomy.

  • Sovereign Defense Installation Exemption: Exempts electric lines, generating plants, and power systems belonging to or under the control of the Armed Forces of the Union from regulatory licensing and control.
  • Protection of Military Communication & Radar Facilities: Ensures that defense radar, electronic warfare, and military communications operate free from civil regulatory interference.
  • National Security Primacy: Subordinates civil electricity regulatory governance to national defense requirements.
Key Landmark Precedents:
  • Power Grid Corp. of India Ltd. v. Century Textiles & Industries Ltd. (2017) 5 SCC 143: Supreme Court recognized that national defense and strategic installations are legitimately shielded from general civilian utility regulations.
  • State of Rajasthan v. Union of India (1977) 3 SCC 592: Affirmed the sovereign constitutional supremacy of defense infrastructure under Union executive control.
  • PTC India Ltd. v. CERC (2010) 4 SCC 603: Affirmed the specialized statutory exemptions protecting sovereign defense operations.
Courtroom Practice & Strategic Litigation Guidance:

Commercial utilities cannot claim rights of entry under Section 163 or demand inspection access over military cantonments, radar bases, or naval dockyards; Section 184 confers complete immunity on defense installations.

Section 183 All 185 Sections of Electricity Act Section 185