1. What is the Sukhdev Singh vs. Bhagatram Sardar Singh Raghuvanshi Case all about?
The Sukhdev Singh vs. Bhagatram Sardar Singh Raghuvanshi case in 1975 addressed the issue of whether statutory corporations created by Acts of Parliament are “State” under Article 12 of the Indian Constitution. The case examined whether employees of these statutory corporations could claim protection under fundamental rights, specifically Articles 14 and 16, against arbitrary actions by their employers.
2. Facts of the Sukhdev Singh vs. Bhagatram Sardar Singh Raghuvanshi Case Relevant for UPSC
- Parties Involved:
- Sukhdev Singh (and others) (petitioners)
- Bhagatram Sardar Singh Raghuvanshi (and others) (respondents)
- Legal Questions:
- Whether statutory corporations like the Oil and Natural Gas Commission (ONGC), Life Insurance Corporation (LIC), and Industrial Finance Corporation (IFC) are “State” under Article 12.
- Whether employees of these statutory corporations are entitled to fundamental rights protections, specifically Articles 14 (Right to Equality) and 16 (Equality of Opportunity in Public Employment).
- Noteworthy Events:
- Employees of ONGC, LIC, and IFC challenged certain service regulations and actions by their employers, claiming these were arbitrary and violated their fundamental rights.
- The corporations contended that they were not “State” under Article 12 and therefore not bound by fundamental rights provisions.
3. What are the Major Judgements/Changes Brought by Sukhdev Singh vs. Bhagatram Sardar Singh Raghuvanshi Case?
The Supreme Court delivered a landmark judgement that significantly impacted the interpretation of Article 12:
- The Court held that statutory corporations like ONGC, LIC, and IFC are “State” under Article 12 of the Constitution. It reasoned that these corporations were created by Acts of Parliament, perform public functions, and have the authority to make rules and regulations that have the force of law.
- The judgement established that employees of these statutory corporations are entitled to the protection of fundamental rights, particularly Articles 14 and 16. This means that the actions of these corporations must comply with the principles of equality and non-discrimination.
- The Court emphasized that statutory corporations performing public duties and functions cannot act arbitrarily and must adhere to the constitutional provisions governing equality and fair treatment in public employment.
4. What was the Impact of Sukhdev Singh vs. Bhagatram Sardar Singh Raghuvanshi Case on Indian Constitution?
- Expansion of the Definition of “State”: The judgement expanded the definition of “State” under Article 12, bringing statutory corporations created by Acts of Parliament within its purview.
- Protection of Employee Rights: It ensured that employees of statutory corporations enjoy the same protections against arbitrary actions as employees in government departments, upholding their fundamental rights.
- Judicial Oversight of Statutory Corporations: The ruling reinforced the principle that statutory corporations performing public functions are subject to judicial oversight to ensure compliance with constitutional provisions.
5. Was this Sukhdev Singh vs. Bhagatram Sardar Singh Raghuvanshi Case Challenged/Reversed in Future?
The principles established in the Sukhdev Singh 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 statutory corporations created by Acts of Parliament and performing public functions are “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.