ISSUE:
Whether an "economic emergency" can be equated with a "public emergency" to justify the invocation of statutory powers under Section 5(1) of the Indian Telegraphs Act, 1885?
Whether administrative action taken without adhering to statutory procedural safeguards, such as independent satisfaction of conditions and prior notice, is valid under law?
RULE:
The term "public emergency" requires an actual and proximate connection to public safety, sovereignty, state security, or public order, and cannot be expanded to include general economic concerns.
When a statute prescribes a specific procedure for exercising discretionary or drastic powers, adherence to those procedural requirements is mandatory, and non-compliance renders the action invalid and arbitrary.