In Life Insurance Corporation of India v. D.J. Bahadur (1981), Krishna Iyer J. explained the maxim…

In Life Insurance Corporation of India v. D.J. Bahadur, (1981) 1 SCC 315, Krishna Iyer J. explained the interpretive principle under generalia specialibus non derogant that 'what is special or general is wholly a creature of the subject and context', holding under the pre-amendment statutory scheme that industrial disputes legislation was the special law for industrial disputes and collective settlements. However, Parliament thereafter enacted the Life Insurance Corporation (Amendment) Act, 1981, inserting Section 48(2)(cc) and Sections 48(2A)–(2C) into the Life Insurance Corporation Act, 1956. Under Section 48(2C), rules framed by the Central Government under Section 48(2)(cc) regarding the terms and conditions of service of employees and agents of the Corporation have overriding effect 'notwithstanding any judgment, decree or order of any court, tribunal or other authority and notwithstanding anything contained in the Industrial Disputes Act, 1947 [now the Industrial Relations Code, 2020; read with Section 8 of the General Clauses Act, 1897] or any other law or any agreement, settlement, award or other instrument for the time being in force'. The constitutional validity of this statutory override was upheld by the Supreme Court in A.V. Nachane v. Union of India, (1982) 1 SCC 205 (and applied in M. Venugopal v. Divisional Manager, LIC of India, (1994) 2 SCC 323).