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CENTRAL UNIVERSITY OF SOUTH BIHAR

SCHOOL OF LAW & GOVERNANCE


PROJECT REPORT-
Original Jurisdiction of the Supreme
Court
UNDER THE SUPERVISION-
Mrs. Poonam Kumari
Assistant Professor

School of Law & Governance

Submitted by-
Rahul Kumar
B.A.LL.B (Hons.)
Enrollment no.-CUSB1813125073

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PREFACE
As a part of LL.B Curriculum (as prescribed by The Bar council of India) and in order to
gain practical cum research knowledge in the field of law .I’m required to make a report on
prescribed topic as per given by the authority(my mentor cum teacher). Here, I have got the
topic ORIGINAL JURISDICTION OF THE SUPREME COURT I required to make a report
on the specified topic .The basic objective behind this project report is to get knowledge
tools of the term and consequences of Indian Constitution.

In this project report I have included various concepts, effects and implications of
ORIGINAL JURISDICTION OF THE SUPREME COURT which came under constitutional
law of India.

Doing this project report it helped me to enhance my knowledge regarding the endorsement
and implications of applying analytical cum factual occurance in this specified term
“ORIGINAL JURISDICTION” so as on which undergoes with many experiences related
with my concerned topic.

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ACKNOWLEDGEMENT

I, Rahul kumar, takes extreme pleasure in expressing my profound gratitude towards my


Constitutional law teacher Mrs. Poonam Kumari(Assistant Professor, Law) for inspiring me
and giving me the invaluable guidance and constant support throughout the course of my
project topic. I have taken efforts in this kind project. However it would not have been
possible without the kind support of my teacher, friends, colleagues and many more
individual persons, writers, college staffs, librarian and other sources of e-resource. I would
like to sincere thanks to all of them.

I thank my parents for providing me everything whatever be required for the completion of
this project.

Finally, I would like to thanks all Kith & Kins who are a little bit part in helping me for this
kind project.

Rahul kumar
B.A.LL.B(Hons.)

Enrollment no-CUSB1813125073

CENTRAL UNIVERSITY OF SOUTH BIHAR

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CONTENT
S no. CONTENT PAGE NO.

Abstract, Hypothesis, Research Methodology 05


1
CHAPTER-1 06-07
2 Introduction

CHAPTER-2 08
3 Position in other countries

CHAPTER-3 09-11
4 History, Limitation and Dispute excluded from 131

CHAPTER-4 12-13
5 Ambit of Article 131

CHAPTER-5 14-15
6 CASE LAWS
CHAPTER – 6 16-17
7 CONCLUSION AND BIBLIOGRAPHY

ABSTRACT

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In India, the Supreme Court has original, appellate and advisory jurisdiction. Its exclusive
original jurisdiction extends to all cases between the Government of India and the States of
India or between Government of India and states on one side and one or more states on other
side or cases between different states. The power of Original Jurisdiction of the Supreme
Court comes under Article 131 of the Constitution of India, 1950 which empowers the apex
court of India to resolve the conflicts between the Centre and the State, State v. State and
Centre v. two or more States.

RESEARCH METHODOLOGY

The research methodology used by me is Doctrinal Research Method. The content is being
taken from library and Internet facilities available for law have been utilized for this project. I
had also followed the steps provided by my subject teacher cum mentor for doing my project
work.

HYPOTHESIS

A court has original jurisdiction when it has authority to hear and determine a case in the first
instance. It has exclusive jurisdiction when it has authority to hear or determine. In a federal
or a quasi-federal structure, which the Indian Constitution sets up, disputes may arisen
between two or more States. A forum should be provided for the resolution of such disputes.
The forum should be the highest court so that final adjudication could be achieved
expeditiously. Article 131 serves that purpose.

CHAPTER -1

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INTRODUCTION
The Supreme Court of India is the highest judicial forum and final court of appeal of India as
established under the Constitution of India, which makes the Supreme Court the highest
constitutional court and guardian of the Constitution. The Supreme Court of India consists of
the Chief Justice of India and 30 other Judges.

Before discussing about Supreme Court’s Jurisdiction let’s define jurisdiction. Jurisdiction
basically means Territory within which a court or government agency may properly exercise
its power.

Jurisdiction generally describes any authority over a certain area or certain persons. In the
law, jurisdiction sometimes refers to a particular geographic area containing a defined legal
authority. For example, the federal government is a jurisdiction unto itself. Its power spans
the entire United States. Each state is also a jurisdiction unto itself, with the power to pass its
own laws. Smaller geographic areas, such as counties and cities, are separate jurisdictions to
the extent that they have powers that are independent of the federal and state governments1 .

Jurisdiction also may refer to the origin of a court's authority. A court may be designated
either as a court of general jurisdiction or as a court of special jurisdiction. A court of general
jurisdiction is a trial court that is empowered to hear all cases that are not specifically
reserved for courts of special jurisdiction. A court of special jurisdiction is empowered to
hear only certain kinds of cases. Jurisdiction can also be used to define the proper court in
which to bring a particular case. In this context, a court has either original or appellate
jurisdiction over a case. When the court has original jurisdiction, it is empowered to conduct
a trial in the case. When the court has appellate jurisdiction, it may only review the trial court
proceedings.

Finally, jurisdiction refers to the inherent authority of a court to hear a case and to declare a
judgment. When a plaintiff seeks to initiate a suit, he or she must determine where to file the
complaint. The plaintiff must file suit in a court that has jurisdiction over the case. If the court
does not have jurisdiction, the defendant may challenge the suit on that ground, and the suit 1
http://www.law.cornell.edu/wex/case 2 http://legal-dictionary.thefreedictionary.com/ Courts
6 may be dismissed, or its result may be overturned in a subsequent action by one of the
parties in the case.

The jurisdiction of the Supreme Court can broadly be categorised as:-

1. Appellate Jurisdiction

2. Original Jurisdiction

3. Advisory Jurisdiction

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Orignial jurisdiction is dealt under Article 131 of the Constitution of India :

Original jurisdiction of the Supreme Court Subject to the provisions of this Constitution, the
Supreme Court shall, to the exclusion of any other court, have original jurisdiction in any
dispute-

(a) between the Government of India and one or more States; or


(b) between the Government of India and any State or States on one side and one or more
other States on the other; or
(c) between two or more States, if and in so far as the dispute involves any question (whether
of law or fact) on which the existence or extent of a legal right depends:
[ Provided that the said jurisdiction shall not extend to a dispute arising out of any treaty,
agreement, covenant, engagements, and or other similar instrument which, having been
entered into or executed before the commencement of this Constitution, continues in
operation after such commencement, or which provides that the said jurisdiction shall not
extend to such a dispute.]

Article 131 of the Indian constitution states the original jurisdiction of Supreme court ,
critically examining the expression “original jurisdiction of Supreme Court” in the article, a
court is said to have an original jurisdiction when it has authority to hear and determine a
case in the first instance. Any kind of dispute may arise between the government of India and
one or more states if we think from the perception of India because of its federal or quasi-
federal structure of the constitution, so a forum is eventually needed for such disputes, Article
131 serves that purpose.

Referring to the original jurisdiction of the Supreme Court of India D.D. Basu said “though
our federation is not in the nature of the treaty or compact between the component units, there
is nevertheless a division of legislative as well as administrative power between union and the
states Article 131 of our constitution therefore vests the Supreme Court with original and
exclusive jurisdiction to determine justiciable disputes between the Union and the States or
between the states inter se”.

CHAPTER -2

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Position of Original Jurisdiction in other countries

ORIGINAL JURISDICTION OF THE SUPREME COURT OF THE


UNITED STATES
Article III, Section II of the Constitution establishes the jurisdiction (legal ability to hear a
case) of the Supreme Court. The Court has original jurisdiction (a case is tried before the
court) over certain cases, e.g., suits between two or more states and/or cases involving
ambassadors and other public ministers.

In the United States, courts having original jurisdiction are referred to as trial courts. In
certain types of cases, the U.S. Supreme Court has original jurisdiction concurrently with
lower courts. The original jurisdiction of the U.S. Supreme Court is governed by Article III,
Section 2 of the United States Constitution and Title 28 of the Unites States Code, section
125.

In the 1793 decision in Chisholm v. Georgia , the Supreme Court sparked controversy when
it ruled that Article III permitted an original suit in the Supreme Court against a state by a
citizen of another state. Congress and the states reacted quickly to what many saw as a threat
to the sovereignty of the states and adopted the Eleventh Amendment to the Constitution,
which prohibited such suits in the federal courts.

The Supreme Court has narrowly interpreted its constitutional grant of original jurisdiction.
In Marbury v. Madison , the Supreme Court ruled that Congress could not expand the Court's
original jurisdiction beyond that granted in the Constitution. Beginning with Cohens v.
Virginia in 1821, the Court held that its original jurisdiction was defined entirely by the
nature of the parties to a suit, not the subject matter. The Court declined to hear in the first
instance cases under the Constitution, laws, and treaties of the United States unless they
strictly conformed to one of the state party suits specified in the Constitution: a suit between
two or more states, between a state as plaintiff and citizens of another state, and between a
state as plaintiff and foreign citizens or governments.

ORIGINAL JURISDICTION OF THE SUPREME COURT OF THE


FRANCE
The lowest court of France has original jurisdiction over most civil matters except areas of
specialist exclusive jurisdiction, those being mainly land estates, business, and consumer
matters, social security, and labor. All criminal matters may pass summarily through the
lowest criminal court, the tribunal de police, but each court has both original and limited over
a certain separate level of offenses.

CHAPTER -3

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Legislative History of Article 131-
It is a known fact that Section 204 of the Government of India Act, 1935 was similar to this
Article 131 of the Indian Constitution. And thus, the case to be discussed is the United
Province v Governor General of Council. This was a case which was filed under section 204
of the Government of India Act, 1935. This section talked about the exclusive original
jurisdiction of the federal court just like the present Article 131 of the Constitution. In this
case the plaintiff brought a case to recover a certain sum of money from the defendant
because it had been wrongly credited to the cantonment fund. But now the defendant said that
the case was not maintainable as a Province could file a case against the Government of India
and that it was not within the original and exclusive jurisdiction of the Federal court. But the
court agreed otherwise and said that in this particular case there was a question which talked
about the legal right of the provinces thus this case was maintainable under section 204 of the
act.

While giving out the judgement Justice Sulaiman said a very interesting thing and this was
“the mere fact that under the previous Act the provincial Governments were subordinate
administrations under the control of the central Government and could only have a
representation to the Governor-General-in- Council or the Secretary of the State would not be
sufficient in itself for holding that the former could not possibly possess any legal right at all
against the Central Government even in respect of rights conferred upon them by the
provisions of the Act or the rules made under”.

Under this section 204 of the Government of India act, 1935 it was construed that the
Provinces could go to the Federal Court to fight for their legal rights but could not go if it was
against the Central Government. A careful reading of the section 204 of the Government of
India Act says that the framers of the act had in mind to make the Federal court the tribunal
of all those disputes which arise between the constituent units of a federation and also
specified the nature of jurisdiction which the court had upon these disputes. The only
limitation which the federal court had at that point was that it could not give out a proper
judgement and that it could only give a declaratory agreement.

Limitation on the exercise of the original jurisdiction by the SC

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The article imposes two limitations on the exercise of the exercise of the original jurisdiction
by the Supreme Court:

First as to the parties, and

Second as to the subject matter.

(1) Parties – There must be an inter-state dispute, i.e. the dispute must be between the units
of the Union or between the Union and any one or more of the States, or between the Union
and any one or more of the States, or between the Union and any State or States on one side
and on one side and one or more States on the other. The idea behind this condition is that if
there is a dispute between two States or between the Union and the States, it is not desirable
that it should be litigated in the court of one of the disputing parties. The Supreme Court in its
original jurisdiction cannot entertain suits brought by private individuals against the
Government of India. Where a private individual has a claim against the Government of
India, the case must go in the first instance to the local courts and from there it can go the
Supreme Court in appeal, provided that the appeal fulfils other requirements of law. In State
of Bihar V. Union of India, the court held that a dispute between the State of Bihar and the
Hindustan steel Ltd., a registered company under the Companies Act, 1956, did not fall
within its original jurisdiction because a body like the Hindustan Steel Ltd. was not “a state”
for the purpose of Article 131.

In suits by the state governments for compensation etc. against the


railway administration, Union of India is a necessary party. These suits, however, cannot be
filed under Article 131 because they do not involve any question with respect to the rights or
claims either of the States o Union as such, but only to rights and claims relating to ordinary
business or commercial transaction which are not in any way different from similar
transactions between private persons. Similarly, a dispute jointly brought by a State with its
agent, who has an independent right to challenge a notification of another state in writ
proceedings, does not fall under this article.

(2) Subject matter- The dispute must involve any question on which the existence or extent of
a legal rights depends. A legal right is an interest recognised and protected by a rule of legal
justice- an interest the violation of which would be a legal wrong done to him whose interest
it is, and respect for which is a legal duty. In United Provinces v. Governor General in
Council, a case under Section 204, Government of India Act, 1935, which defined the
exclusive original jurisdiction of the Federal Court in a language similar to that used in the
present article, the Federal Court held that although a legal right is commonly accompanied
by the power of instituting legal proceedings for the enforcement of it, yet it is not necessarily
the case and does not pertain to the essence of the conception. But where the claim made by a
party is dependent not on law but on non-legal considerations, the court has no jurisdiction
under Article 131.

DISPUTE EXCLUDED FROM ARTICLE 131

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The exclusive jurisdiction conferred on the Supreme Court under this article is subject to the
other provisions of the Constitution. In the following matters, the exclusive jurisdiction of the
Supreme Court is excluded by the constitution:

1. The proviso to Article 131 declares that the jurisdiction of the Supreme Court does not
extend to a dispute arising out of any treaty, agreement, covenant, engagement, sanad or other
similar instrument which, having been entered into or executed before the commencement of
the Constitution, continues in operation after such commencement, or which provides that the
jurisdiction shall not extend to such a dispute. A dispute involving these documents has
evidently been left within the exclusive discretion of the executive.

2. Parliament may by law exclude the jurisdiction of the Supreme Court in disputes between
States with respect to the use, distribution or control of waters of any inter-state river valley.
In such disputes, different modes of adjudication may be prescribed. Inter-state Water
Dispute Act, 1956 enacted by parliament under Article 262 is such a legislation. An
agreement falling under this provision and can be entertained by the court under Article 131.

3. Matters referred to the Finance Commission.

4. Adjustment of certain expenses between the Union and the States.

The Union of India and each one of its States is treated as a person in the
eyes of law. A State may sue and be sued. The Government of India may sue or be sued by
the name of the Union of India. The Government of a State may sue or be sued by the name
of the State.

CHAPTER -4

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Ambit of the court under Article 131 and what are legal rights? -
Thus, the ambit of Article 131 is not that wide as disputes that arise between the departments
of the Union Government and the State Government do not fall within the meaning of the
word ‘State’.

Now, the Article itself starts with the phrase “Subject to the provisions of this
Constitution…” which means that Parliament can make laws which will actually effect the
jurisdiction of the court, like it has done in the case of inter-State water disputes (Article 262
of the Constitution). So, by the commencement of the Inter-State Water Dispute Act, 1956
the parliament actually gave the powers to the tribunal to resolve the conflicts between the
States but when the time comes for the binding of the award then the Supreme Court gets the
powers as now the dispute is between the States and the water conflict has been solved and it
is no longer within the ambit of Article 262.

So, in the case of State of Rajasthan v UoI it was said that the Supreme Court has got the
power to give any kind of relief if it is necessary to enforce the legal right of any State on
dispute if such legal right has been established by the Government of the State.

As mentioned by the author earlier that this Article 131 suffers from 2 kinds of limitations
and one of them being the subject matter of the dispute i.e. only those case between the
Governments can be entertained by the Supreme Court which are based on the legal rights of
the State Government or the Union Government. As it has been said by Salmond that a “a
legal right is an interest recognised and protected by the rule of legal justice – an interest the
violation of which would be a legal wrong done to him whose interest it is, and respect for
which is a legal duty”.

The definitions of legal rights by Holland is as follows-“If irrespectively of his having, or not
having, either the right, or moral right on his side, the power of the State will protect him in
so carrying out his wishes, and will compel such acts or forbearance on the part of other
people as may be necessary in order that his wishes may be so carried out, then he has a
“legal right” so to carry out his wishes.”

Thus, for any case to be entertained by the Supreme Court under Article 131 of the
Constitution what has to be kept in mind is that the controversy which is arising or the
question which is asked must be based on the legal rights of someone (only a State
Government or the Central Government) and any kind of non-legal questions is not
maintainable.

This is what was also held in the Rajasthan Dissolution case that the suit filed was
maintainable because of the fact that the suit was trying to enforce the legal right of the State
as there had been a gross in violation of their legal rights due to the power (unconstitutional
exercise of power) used by the President under Article 356 of the Constitution which lead to
the infringement of the rights of the individual members of the Legislative Assembly and the
rights of the State as well. Another question that was asked in this case was whether the word
State Government was included within the meaning the ‘State’? So, the majority in this case

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said that whenever there is a case under this Article 131 then it means that there is a dispute
between the Central Government and the State Government and it does not mean that there is
a dispute between the offices in the Government. It is not the political parties that should be
fighting, it is the whole Government per se that is fighting against the violation of some of
their legal rights. Article 131 gives both the Governments a forum to fight on legal issues and
not on mere political issues. Thus, the order given by the Government of India to the State
Governments ordering the Chief Minister to tender advice to the Governor of the State is not
a mere political issue but a legal right.

Now what the majority of the judges say in this case is that it is not necessary that in every
case being filed under this Article that the State Government or the plaintiff has to prove that
their legal right is being violated but they can also question the legal right or the
Constitutional validity of any action taken by the Union Government or the State
Government or the defendant per se.

The minority in this case had a different view and they said that the word “State” didn’t
include within itself the State Government. They said that a dispute between the Government
of India and any StateGovernment will not come under the purview of Article 131 as even
after the Assembly is dissolved, still the State will continue to have a Government.

The author would like to point out the fact that according to Article 300 of the Indian
Constitution it has been explicitly mentioned that the Government of India will be sued or
will sue under the name of the Union of India and that the StateGovernment will be sued or
will sue under the name of the State only. The explanation of this Article says that there is a
difference between the terms Union of India and Government of Indiaand that the latter is not
a legal entity and that the former is, which is like a corporate body with rights and
obligations. The same way even the State has been given a juristic personality with power to
sue and to be sued. It also mentions an exception that except in Article 131 of the
Constitution every suit involving the Government and its employees will be seen by the other
ordinary courts

CHAPTER -5

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Case laws
1. In the case of State of Karnataka v UOI - J. Bhagwati emphasises on the point that all the
cases which are under Article 131 of the Constitution should only talk about the legal rights
of either of the parties, any kind of non-legal aspect will not be entertained. Thus, defining
the scope of Article 131 the hon’ble judge said “What has, therefore to be seen in order to
determine the applicability of Article 131 is whether there is any relational legal matter
involving a right, liberty, power or immunity qua the parties to the dispute. If there is, the suit
would be maintainable but not otherwise.

Article 131 does not lay down any particular mode of proceeding for exercise of the original
jurisdiction conferred by it. Although the Supreme Court Rules contemplate that the original
jurisdiction of the Court under this Article shall be invoked by means of a suit that is not the
requirement of the Article. While interpreting the Article one is perhaps unconsciously
influenced to import the notion of cause of action which is germane in a suit and read this
Article as limited only to cases where some legal right of the plaintiff is infringed and
consequently it has a cause of action against the defendant. But there is no reference to a suit
or cause of action in Art. 131. That Article confers jurisdiction on the Supreme Court with
reference to the character of the dispute which may be brought before it for adjudication. The
requirement of cause of action, which is so necessary in a suit, cannot be imported while
construing the scope and ambit of Art.

It is well-established that a Minister is an officer subordinate to the Governor. The enquiry


set up in this case is not against the State or the State Government, but against the Chief
Minister and other Ministers to whom it is open to move the High Court under Art. 226 of the
Constitution and the High Court would then have referred the question of vires of the Act to
the Supreme Court under Art. 131A. But, that in no way entitles the State to invoke the
original jurisdiction of the Supreme Court under Art. 131.

2. In the case of State of Bihar v UOI- when the State of Bihar had filed a suit against the
Central Government on behalf of the Railways wanting some kind of compensation then the
Supreme Court said that this case was not maintainable as the question of legal rights of a
private consignor was risen thus it was outside the jurisdiction mentioned under Article 131.

3. In the case of Tashi Delek gaming solutions Ltd v State of Karnataka,- The lottery
agents of the States Sikkim and Meghalaya challenged the banning of lottery games by the
State of Karnataka. The Karnataka High Court held that this dispute held the legal rights of
all the three States, hence the remedy will be under article 131 only. But the Supreme court
held otherwise and said that these agents were given the right to represent the State
Governments and hence were private parties thus not coming under the jurisdiction of article
131. Such an agent had the right to sue and be sued in his own name and thus it would not
come under this article 131.

4. Article 131 talks about State disputes, but the word ‘State’ does not have the same meaning
like that in Article 12 of the Indian Constitution. Under Article 12 there are many
organizations that can be qualified as a State if they fulfill the 6 conditions given in the Ajay

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Hasia v Khalid Mujib Case . Thus, it means that private parties are not be a part of the cases
which fall under Article 131 which is resolved by the Supreme Court.

5. Original jurisdiction is in the matters of the election disputes as mentioned earlier and the
exclusive jurisdiction because it is the only the Supreme court is the only court in India that
has the power to settle disputes between the State Government and the union Government or
between more than one StateGovernments. This was given in Union of India v State of
Rajasthan.

6. Raleigh Investment Co., Ltd. vs Governor-General In Council. on 9 April, 1943-The


plaintiffs claim in this suit is first to have Explanation (3) to Section 4(1)(c) together with
relevant words of Section 4(1)(c) declared invalid, and then the return of the money they have
paid together with other connected reliefs. A decision in this suit will clearly affect the
amount of money the Government will be able to collect as income-tax both in the year in
question and in subsequent years. The suit would therefore appear to be one "concerning the
revenue". It is necessary however to consider what the word "revenue" means. In 1781, when
prohibition against the Supreme Court exercising original jurisdiction in matters concerning
the revenue clearly meant income from land, but in 1935, when prohibition against the
Supreme Court exercising original jurisdiction in matters concerning the revenue was first
introduced into the Act of Settlement, revenue clearly meant income from land, but in 1935,
when the same provision was substantially re-enacted, revenue, in view of the provisions of
Sections 136 and 138 of the Act of 1935, would clearly include money derived from income-
tax.

7. In United Provinces v. Governor General in Council, a case under Section 204,


Government of India Act,1935, which defined the exclusive original jurisdiction of the
Federal Court in a language similar to that used in the present article, the Federal Court held
that although a legal right is commonly accompanied by the power of instituting legal
proceedings for the enforcement of it, yet it is not necessarily the case and does not pertain to
the essence of the conception. In that case, the plaintiff brought a suit against the defendant
for the recovery of certain sums of money, which he alleged were wrongfully credited to the
cantonment fund. The defendant, inter alia, pleaded that since no suit could be instituted by
Province against the Government of India under the law prevailing at the relevant period, the
dispute was one which was not justiciable before the Federal Court held that suit would lie,
because the dispute involved a question on which the existence or extent of a legal right
depend.

Conclusion

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What has been understood so far is that Article 131 is the original and the exclusive
jurisdiction of the Supreme Court of India when it is looking at the disputes which has been
rising which has risen between the Union and State or between two states. No High court in
India has that kind of jurisdiction. There are basically two important things that has to be kept
in mind and that is parties to the dispute can only be a state (federal units) or the Union
Government itself. The meaning of the word State in article 131 is not the same as or as wide
as given Article 12 of the constitution that means that a corporate body or a private body
which is treated as a state will not be treated as a state under article 131 of the Constitution.
The next important thing is that only the legal rights of the State are to be considered and not
the political rights. All disputes that are not in the category of legal rights of the State then
immediately it is outside the jurisdiction of the court under Article 131.

The confusion which arose was whether the State Government will be the same and that
answer has now been answered in the affirmed as it is one and same and it has also been
explicitly mentioned in article 300 of the Constitution.

What is a legal right and what is not has been given explicitly anywhere but the courts
according to their discretion while resolving cases determines whether a right is a legal right
or a political right of a state.

Concluding the entire topic, according to the author article 131 of the constitution shall be
reasonably interpreted and the Supreme Court of India shall be considered as an exclusive
jurisdiction, and if any question related to the power distribution arises when one of the party
should be that of government.

SUGGESTIONS

BIBLIOGRAPHY

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BOOKS

 V N Shukla (2013)12th edition Constitution Of India, Lucknow: Eastern book


company
 M P Jain (2010) 6th edition, Indian Constitutional Law: Lexis Nexis
 Ratanlal and Dhirajlal’s Constituion of India
 DD Basu’s Shorter Constitution of India

Website

 www.legalbites.in
 Wikipedia
 www.indiankanoon.in
 www.advocatekhoj.com
 www.indianjudiciary.com

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