Article 152(1) has given a particular meaning of "administrative unit". It means "a district or other area designated by law for the purposes of Article 59". Local government in every administrative unit, therefore, means a local government either in a district or in any other area specifically designated by law. Learned Attorney‑General's contention is that for the purpose of establishing a Local Government in a district, the district should also be designated as an administrative unit. Mr. Ishtiaq Ahmed differs from this view and argues that as a 'district' has been specifically included in the definition of "administrative unit", no separate designation is necessary for setting up a local government there. He further contends that as upazilas, unions and municipalities are within the territorial 'limit' of a district, no separate designation of these areas also is necessary for establishing local governments there. He has tried to argue that if any local government is to be established in an area involving more than one district, then only a designation of that area as an administrative unit will be necessary. For true construction of Article 152(1) defining an 'administrative unit' the primary rule of construction will be sufficient in this case. It is the words used in this Article which will give its meaning. The words in this Article are simple, clear and unambiguous, and on reading these words together a definite meaning emerges. For the purpose of finding out the legislative intention behind this provision no further effort need be made. In this Article the words "district or any other area" are to be read conjunctively, and if it is done, a "district" is found to be an administrative unit, and for the purpose of Article 59, that is to say, for establishing a Local Government there, no designation by law is necessary. But as regards "any other area" it will be an "administrative unit" only if it is specifically designated as such by law. 

( Kudrat-E-Elahi Panir Vs. Bangladesh, 1992, 21 CLC (AD) [1053] )

See also 

Bangladesh Legal Aid and Service Trust (BLAST) Vs. Bangladesh & another, 2005, 34 CLC (HCD) [7861]

Mohammad Badiuzzaman Vs. Bangladesh and Others, 2010, 39 CLC (HCD) [7907]