1. What is the Rajasthan State Electricity Board vs. Mohan Lal Case all about?
The Rajasthan State Electricity Board vs. Mohan Lal case in 1967 addressed the issue of the applicability of Article 12 of the Indian Constitution to statutory authorities and the definition of “State” under the Constitution. The case examined whether the Rajasthan State Electricity Board, a statutory body, could be considered “State” within the meaning of Article 12, making it subject to the fundamental rights guaranteed by the Constitution.
2. Facts of the Rajasthan State Electricity Board vs. Mohan Lal Case Relevant for UPSC
- Parties Involved: Rajasthan State Electricity Board (appellant) vs. Mohan Lal and others (respondents).
- Legal Questions:
- Whether the Rajasthan State Electricity Board is “State” under Article 12 of the Indian Constitution.
- Whether the actions of the Rajasthan State Electricity Board are subject to fundamental rights, particularly Articles 14 and 16.
- Noteworthy Events:
- Mohan Lal, an employee of the Rajasthan State Electricity Board, challenged certain service regulations and disciplinary actions taken against him, arguing that they violated his fundamental rights.
- The Board contended that it was not “State” under Article 12 and, therefore, not subject to the fundamental rights provisions.
3. What are the Major Judgements/Changes Brought by Rajasthan State Electricity Board vs. Mohan Lal Case?
The Supreme Court delivered a landmark judgement with significant implications for the interpretation of Article 12:
- The Court held that the Rajasthan State Electricity Board is “State” under Article 12 of the Constitution. It ruled that any authority created by the Constitution or by law, which has the power to make laws or perform functions of a governmental nature, falls within the definition of “State.”
- The judgement established that the Board, being a statutory authority created under the Electricity (Supply) Act, 1948, performs public functions and is subject to the fundamental rights guaranteed by the Constitution.
- The Court emphasized that all statutory bodies and authorities that perform public duties and have governmental functions must adhere to the constitutional provisions, particularly fundamental rights.
4. What was the Impact of Rajasthan State Electricity Board vs. Mohan Lal Case on Indian Constitution?
- Broadening the Definition of “State”: The judgement broadened the definition of “State” under Article 12, ensuring that a wide range of statutory authorities and bodies are subject to fundamental rights.
- Protection of Fundamental Rights: It reinforced the protection of fundamental rights by bringing more entities under the purview of the Constitution, ensuring that their actions comply with the principles of equality and non-discrimination.
- Judicial Oversight of Statutory Bodies: The ruling established that statutory bodies performing public functions are accountable to the judiciary for any violation of fundamental rights.
5. Was this Rajasthan State Electricity Board vs. Mohan Lal Case Challenged/Reversed in Future?
The principles established in the Rajasthan State Electricity Board case have been upheld in subsequent legal proceedings and continue to guide the interpretation of Article 12 of the Indian Constitution. The judgement remains a key reference for determining whether an entity falls within the definition of “State.”
6. Doctrines/Theories/New Concepts
- Doctrine of State Under Article 12: The case introduced the principle that any authority created by the Constitution or by law, which performs governmental functions, falls within the definition of “State” under Article 12. This doctrine ensures that a wide range of public authorities are subject to constitutional provisions, particularly fundamental rights, promoting accountability and adherence to the principles of equality and non-discrimination.