State of U.P v. Radhey Shyam Rai is a 2009 constitutional law case before the honourable Supreme court of India concerning the interpretation of the meaning of “state” under Article 12 of the Indian constitution and its applicability to a cooperative society- Uttar Pradesh Ganna Kishan Sansthan.
FACTS:
- The petitioner (respondent) in this case worked as a data processing officer in the Uttar Pradesh Ganna Kishan Sansthan, an establishment of the government, which performed functions like imparting training and knowledge to cane farmers and related persons with the motive of increasing the production of sugar by the state, initially performed by the Cane Development Department.
- On 28th April 1997, the society’s governing council abolished the Data Processing officers’ posts, and whereto the services of the respondent were dismissed.
- Aggrieved by this decision, he filed a writ petition before a divisional bench of the Allahabad High Court, which was dismissed.
- This decision was reversed by a full-bench judgment of the same court, finding that the UP Ganna Kishan Sansthan is a state within Article 12 of the Constitution.
- Hence, the State of U.P filed this appeal to the Supreme Court.
ISSUES:
- Whether the Uttar Pradesh Ganna Kishan Sansthan, a society registered under the Societies Registration Act of U.P, a `State’ within the meaning of Article 12 of the Indian constitution?
RATIO DECIDENDI:
- The issue was taken up by a two-judge Supreme court bench, comprising Justice S.B. Sinha and Justice Cyriac Joseph.
- The court observed that the Sansthan depends on the state from an administrative and functional point of view. This is based on the evidence that the majority of the members of the governing council held different offices of the state government, and it had to follow the orders of the state government from time to time.
- Financially too, it was found that the funding of the state government meets almost 80% to 90% of the expenditure of Sansthan.
- The main aim of Sansthan, viz., is to impart training and knowledge to cane farmers, with the motive of increasing the production of sugar by the state, which is a state function.
DECISION:
- Based on the observations mentioned above of the financial, administrative aspects, and objectives of Sansthan, they found it to be a ‘State’ within the meaning of “other bodies” under Article 12 of the Constitution of India.
- The appeal filed by the state of U.P was dismissed, upholding the decision of the High Court.
CONCLUSION:
- Through this 2-judge bench, the Supreme Court has re-iterated the previous, well-settled rulings in Rajasthan State Electricity Board v. Mohan Lal; Ajay Hasia v. Khalid Mujib Sehravardi, and the most famous case of Pradeep Kumar Biswas v. Indian Institute of Chemical Biology, clearing any ambiguity left with cases relating to the applicability of Article 12 of the Indian Constitution.
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