Sec. 3 of the IESO Act, 1946 mandates submission of Draft Standing orders within 6 months to the certifying officer from the date of applicability of the Act to a particular industrial establishment. Sec. 13 imposes a penalty over the erred employer who fails to submit the draft standing orders under Sec. 3 of the Act to the certifying officer. Sec. 12A speaks for deemed adoption of Modal standing orders from the date on which this Act becomes applicable and ending with the date on which the SOs finally certified by the Certifying officer by using the words "not withstanding anything contained in Sec. 3 to 12". Is Sec. 12 A not contradictory to Sec. 3? Does Sec. 12 not send wrong signals to industries that there is no necessity to design Standing orders of their own and mere dwelling upon Modal standing orders for decades is enough? In such case is there any possibility to take up prosecution against any of the employer for violating Sec. 3? Pl. discuss..Kesava Panda