State Action or Not: Explaining ‘State’ under Article 12 of the Constitution (Part 2)

By Pranika Goel

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Other Authorities

The principal reason for ambiguity in the definition of state is this term “other authorities”. Numerous judicial interpretations have been evolved over the years to understand the meaning of the term.

Earlier, the Ejusdem Generis rule was applied to interpret the term. This rule states that when a general term is used after some specific terms, the former is to be interpreted to belong to the same general category as do the latter. Hence, in University of Madras v. Shantha Bai[1], the Madras High Court ruled that ‘other authorities’ includes only those bodies which have the same powers as the terms used before that, that is, sovereign powers.

Next, in Rajasthan Electricity Board v Mohanla1[2], the Supreme Court overruled the Shantha Bai judgement and held that ‘other authorities’ includes any body which is statutorily or constitutionally created, and on which powers are conferred by law. However, in the concurring judgement, Justice Shah adopted a different test to hold the electricity board as state. He was of the opinion that the essential test here is of sovereign power with the authority, which he defined as “power to make rules or regulations and to administer or enforce them to the detriment of citizens”.

In Sukhdev Singh v. Bhagatram[3], the test of instrumentality or agency of state was developed. Mathew, J., who wrote the concurring judgement, called the three public corporations- ONGC, LIC and IFC, as functionalities of the state. The state, assuming a welfare role under Part IV of the Constitution, behaved also as a ‘service corporation’ and hence any corporation acting as an arm of the state, aiding it in discharging its welfare obligations would qualify as ‘other authorities’ under Article 12. He concluded by saying that a body would be ‘an agency or instrumentality of the state’ if it performs public function, that is, a function that has wide import on the public at large, which is closely related to government functions.

Next was the Government Control Test established in the R.D. Shetty v. International Airport Authority[4]. Borrowing the agency and instrumentality test, it was added that if the entity is financially aided by the government; what degree of control, if any, the government enjoys over its management and policies; whether it enjoys a monopoly status, which is conferred or protected by the government. The cumulative effect, rather than an affirmative answer to any one of these questions would be of relevance. The public function test was also reiterated.

A clear and distinct test to determine what is an agency or instrumentality of state was established by Bhagwati J. in Ajay Hasia v. Khalid Mujib[5]. The test involved the following six considerations:

  1. whether the entire share capital of the corporation is owned by the Government;
  2. whether the financial assistance given by the State is enough to cover the entire expenditure of the entity;
  3. whether the Corporation enjoys a monopoly status which is either Government conferred or Government protected;
  4. whether there is existence of deep and pervasive State control;
  5. whether the functions of the entity are of public importance or closely related to Governmental functions;
  6. whether a Government department is transferred to a corporation.

According to this test, it was not necessary that the body is statutorily established. Again, the cumulative effect of these considerations was to be seen.

This test was further elaborated upon in Pradeep Kumar Biswas v. Indian Institute of Chemical Biology[6], wherein it was held that rather than focussing on any one of the aforementioned considerations, the principal question to be determined was whether on an analysis of facts, the body in question is under the financial, functional and administrative control of the government, and whether such control is pervasive and not merely regulatory.

As is quite evident from these precedents, the judicial approach to the issue of what is state is quite haphazard and unsatisfactory. It is more relevant to take each case on the basis of its fact and then arrive at a conclusion. Hence, some examples of other authorities as arrived upon by various court decisions include Public Corporations like SBI, SAIL, Food Corporation of India etc.; government companies, nationalized banks, and so on.

 

within the territory of India or under the control of the Government of India

The final phrase to be examined is “within the territory of India or under the control of the Government of India”. The phrase is used with connection to ‘local or other authorities’. As is evident from the use of the word ‘or’, the clause is a disjunctive one, that is, satisfaction of either one of them would fall within the ambit of the section. Thus, “under the control” means that even those bodies falling outside the territory of India, but under the control of the government could be included as state under the article. Hence it is wider than “within the territory”, which may be interpreted to mean such entities which are not under the control of the government, but perform public function. However, the courts have been hesitant is bestowing this interpretation upon this phrase.

 

Conclusion

Fundamental Rights enshrined in Part III of the Constitution are only enforceable against the State, as defined in Article 12. The definition has been a matter of judicial scrutiny over the years, primarily due to the use of the term ‘other authorities’. The test guiding the determination of the same seems to be deep and pervasive government control. However, in the opinion of the author, public function test is more apposite to realise the true objectives of Fundamental Rights. This would enable even those actions of private entities which come within the domain of public function and infringe upon the rights of an individual. It is hoped that the future jurisprudence on the issue is more liberal and favourable to the interests of the individuals, which are unequally disposed as compared to these powerful entities.



[1] AIR 1954 Mad 67

[2] 1967 SCR (3) 3771.

[3] AIR 1975 SC 1331.

[4] 1979 SCR (3) 1014.

[5] 1981 AIR 487.

[6] (2002) 5 SCC 111


Back to Part 1.


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Pranika Goel is a 2nd year Law student at National Law University, Delhi. Still exploring what her true calling is, she is interested in Constitutional Law, Criminal Law, Corporate Law and Cyber Law. She likes to read fiction, paint and cook to de-stress. A curious soul, she enjoys studying about other fields, particularly Positive Psychology and Mathematics.

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