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Case Analysis 2nd Assignment
Case Analysis 2nd Assignment
CASE ANALYSIS ON
SUKHDEV SINGH V. BHAGATRAM, AIR 1975 SC 1331
SHIRIN RAZDAN
A) ABSTRACT / HEADNOTE
Issue: Bhagat Ram Singh was dismissed by a corporation under statutory laws like the Oil
and Natural Gas Commission Act, 1959.
Action: Bhagat Ram appealed to the High Court, which deemed his dismissal unlawful and
ordered his reinstatement.
Ruling: The corporation, acting as a state function, was considered a state entity. Rules set by
it lacked legal authority.
Significance: The case broadened Article 12's 'State' definition to include statutory
corporations. It affirmed their regulations as legally binding, making their employees state
servants.
Keywords: Sukhdev Singh v. Bhagatram, Article 12, Statutory Corporations, Force of Law,
Servants of Union or State.
B) CASE DETAILS
1. The case, headed over by a panel consisting of five justices, including Justices A.N. Ray,
K.K. Mathew, Y.V. Chandrachud, A. Alagirisamy, and A.C. Gupta, focused on the
termination of employee Bhagat Ram Singh Raghuvanshi by a corporation governed by
LAWFOYER
legislative statutes, particularly the Oil and Natural Gas Commission Act, 1959; the
Industrial Finance Corporation Act, 1948; and the Life Insurance Corporation Act, 1956.
2. Bhagat Ram filed a civil appeal with the High Court, seeking restitution and
reinstatement. The High Court ruled that his dismissal was unfair and issued a writ of
mandamus to reinstate him. It determined that the corporation functioned as a state entity.
G) RESPONDENT’S ARGUMENTS
1. Concerning the termination's legality, they asserted that Bhagat Ram Singh removal
following the businesses' established procedures.
2. Concerning whether statutory companies should be deemed 'State,' they contended that
these institutions do not qualify as 'State' or 'authority' under Article 12 of the
Constitution
3. Regarding the status of regulations, they argued that the corporation's policies and
procedures lacks legal effect.
LAWFOYER
Article 14 of the Constitution of India: This article guarantees equality before the law and
equal protection of the laws within the territory of India.
Article 16 of the Constitution of India: This article provides for equality of opportunity in
matters of public employment.
I) JUDGEMENT
a. RATIO DECIDENDI
Article 12 of the Constitution designates statutory corporations, such as the Oil and Natural
Gas Commission, the Industrial Finance Corporation, and the Life Insurance Corporation, as
"State" institutions. As a result, the rules they create have the same legal force as laws. If an
employee's termination is in violation of these regulations, they have the ability to assert their
employment status.
A seminal ruling in the Indian legal system, Sukhdev Singh v. Bhagatram (AIR 1975 SC
1331) considerably broadened the meaning of "State" under Article 12 of the Constitution to
encompass statutory corporations. The ruling declared that rules issued by statutory
corporations are binding on the Union or the State, and that workers of such corporations are
considered to be their slaves.
K) REFERENCES
a. Important Case Referred
Sabhajit Tewary v. Union of India (1975) 3 SCR 616 is an important legal case that pertains
to the understanding of Article 12 of the Indian Constitution, delineating the concept of
"State."
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