Bank Nationalization – Policy Analysis

Project Type 3

SUBJECT

Economics-II

SUBMITTED TO
Prof. Amirullah Khan

SUBMITTED BY

Trayi Reddy

BA. LLB (Hons.)

3rd semester - Section B
Roll number: 43
 Table of Contents

Introduction ........................................................................................................................... 2
Rustom Cavasjee (R.C. Cooper) v. Union of India, 1970: The Landmark Bank Nationalization
Case ....................................................................................................................................... 5
State Bank of India (SBI) Act of 1955: Paving the Way for Banking Reforms in India ............... 8
Bank Nationalization in India: The Legislative and Constitutional Context .............................11
R.C. Cooper v. Union of India: A Pioneering Landmark in Indian Constitutional Law...............13
Viewpoint | The nationalization of banks in 1969 had adverse consequences for India rather
than benefiting the country. ..................................................................................................16
Conclusion .............................................................................................................................19
Citations ................................................................................................................................21

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Introduction

The nationalization of banks in India is a pivotal moment in the country's economic history. It is
a policy that has significantly shaped the financial landscape of the nation. The move towards
bank nationalization, primarily occurring in two phases in 1969 and 1980, was rooted in the
government's desire to democratize credit access, promote economic development, and address
the issue of skewed credit distribution. This essay provides an in-depth analysis of the bank
nationalization policy in India, discussing the laws, articles, and facts that underpin this
transformative decision.

Before delving into the specifics of bank nationalization, it is crucial to understand the socio-
economic and political environment that led to this policy. In the early post-independence period,
the Indian banking sector was dominated by a few large private banks, which catered primarily
to the needs of industrialists and affluent sections of society. Rural and agricultural sectors, as
well as small and medium-sized enterprises (SMEs), were largely neglected.

Phase I: 1969 Bank Nationalization

1. The Banking Companies (Acquisition and Transfer of Undertakings) Act, 1969: This
legislation provided the legal framework for the first phase of bank nationalization. Under this
act, 14 major commercial banks were nationalized.

2. Article 40(b) of the Directive Principles of State Policy: The Constitution of India, in Article
40(b), directs the State to take steps to ensure the functioning of banks and financial institutions
to secure the principle of "equal pay for equal work."

3. Objectives: The primary objectives of the 1969 nationalization were to extend banking
services to rural and semi-urban areas, promote priority sector lending (agriculture, small-scale
industries, and exports), and reduce regional disparities.

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4. Impact: This phase of nationalization led to the expansion of bank branches in rural areas,
increased agricultural credit, and improved access to credit for marginalized sections of society.
It also helped in curbing the concentration of economic power.

Phase II: 1980 Bank Nationalization

1. The Banking Companies (Acquisition and Transfer of Undertakings) Act, 1980: This act built
upon the earlier legislation and led to the nationalization of six more banks. It aimed to further
the social and economic objectives set by the government.

2. Articles 43A and 46 of the Directive Principles of State Policy: These articles emphasize the
State's role in promoting economic and social justice, which includes ensuring equitable
distribution of wealth and resources.

3. Objectives: The 1980 nationalization aimed to strengthen the banking sector's stability,
promote social banking, and support the government's poverty alleviation programs.

4. Impact: The second phase reinforced the banking sector's stability, and the government's
control over banks allowed it to direct credit towards sectors that needed it most. This phase also
saw the establishment of Regional Rural Banks (RRBs), further enhancing rural credit access.

Bank nationalization has had a lasting impact on the Indian banking sector. As of my last
knowledge update in September 2021, the majority of banks in India remained under government
control. However, there were discussions about the need for reforms to address issues such as
non-performing assets (NPAs) and improving the efficiency of public sector banks.

While the nationalization of banks has brought about significant positive changes, it has also
faced challenges. Over the years, inefficiencies, politicization, and issues related to the autonomy
of public sector banks have been debated. The government and regulators have been working on

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banking sector reforms, including mergers and consolidation of public sector banks, to address
these concerns.

The nationalization of banks in India, carried out in two phases in 1969 and 1980, was a bold and
transformative policy decision. It was rooted in the principles of economic and social justice
enshrined in the Constitution and aimed to promote financial inclusion, reduce regional
disparities, and support economic development. The legal framework and articles in the
Directive Principles of State Policy provided the necessary foundation for these policies. While
challenges persist, the impact of bank nationalization on India's economic and social fabric is
undeniable, and its legacy continues to shape the nation's financial sector.

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Rustom Cavasjee (R.C. Cooper) v. Union of India, 1970: The
Landmark Bank Nationalization Case

Introduction

Rustom Cavasjee Cooper, commonly referred to as R.C. Cooper, vs. Union of India, 1970, is a
pivotal legal case in Indian banking law that holds a distinguished position in the annals of
India's legal and constitutional history. The case, popularly known as 'The Bank Nationalization
Case,' bears immense significance for Indian jurisprudence and is intrinsically intertwined with
the principles of the Indian Constitution. This case is primarily remembered for challenging the
nationalization of banks in India in the late 1960s, a historic policy shift initiated by the
government.

The Bank Nationalization Policy

The backdrop of this landmark case revolves around the nationalization of major Indian banks in
1969. The policy, put into action through The Banking Companies (Acquisition and Transfer of
Undertakings) Ordinance, 1969, led to the government's acquisition of 14 prominent banks.
These banks, including the Central Bank of India, in which R.C. Cooper was a director, and the
Bank of Baroda, in which he held shares, were transformed into public sector entities.

Challenging the Nationalization

R.C. Cooper, feeling aggrieved by this nationalization policy and the inherent provisions,
particularly Schedule II of the Ordinance, decided to challenge the government's actions.
Schedule II stipulated that in the event of the government acquiring a bank, the compensation to
be paid to the shareholders would be determined through an agreement. If such an agreement
failed, the matter would be adjudicated by a tribunal. Furthermore, as per the Schedule, even
after the tribunal's verdict, the compensation would only be disbursed after ten years, starting
from the date of the agreement's failure.

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Legal Battle

R.C. Cooper's legal challenge against the Union of India was a formidable undertaking. The case
witnessed two eminent legal advocates representing both sides. Senior Counsel Nani Palkhivala,
a highly regarded legal luminary, represented R.C. Cooper. On the government's side, the Union
of India was represented by the then-Attorney General, Niren De, and Solicitor General, Jagdish
Swarup. The weight of legal acumen and constitutional interpretation was brought to bear upon
this critical litigation.

The Verdict

The case of R.C. Cooper vs. Union of India, 1970, was heard by an illustrious bench of eleven
judges. The judgment was delivered, and it tilted overwhelmingly against the provisions of the
Ordinance. A notable 10:1 majority favored the petitioner, R.C. Cooper, marking a significant
legal victory in his challenge against the nationalization policy.

Implications and Significance

The R.C. Cooper case's verdict was a significant turning point in Indian legal history, reiterating
the supremacy of the Constitution and the principles of justice and fairness it upholds. The case's
importance extended beyond its direct impact on bank nationalization; it emphasized the need for
constitutional rigor in policy decisions and the protection of the rights of individuals and
corporations against arbitrary state actions.

The judgment also acted as a safeguard against excessive state control and illustrated the
judiciary's commitment to uphold the principles of justice and rule of law. In the broader context,
it became a symbol of resistance against unchecked government authority and further solidified
the constitutional framework of India.

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The R.C. Cooper vs. Union of India case of 1970, famously known as 'The Bank Nationalization
Case,' will forever hold a distinguished place in India's legal and constitutional history. R.C.
Cooper's challenge against the government's bank nationalization policy and its pivotal
provisions brought forth an essential legal precedent that emphasized the importance of
constitutional safeguards and the protection of individual and corporate rights. This landmark
case serves as a testament to the vitality of the Indian Constitution and the enduring commitment
of the judiciary to uphold its principles.

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State Bank of India (SBI) Act of 1955: Paving the Way for Banking
Reforms in India

The year 1955 witnessed a significant milestone in India's banking history with the passage of
the State Bank of India (SBI) Act. This legislation, while formally establishing the State Bank of
India, was emblematic of a broader strategy to transform the banking landscape in the young
Indian republic. The groundwork for this transformation had already begun with the
government's acquisition of the Imperial Bank of India, a precursor to the State Bank of India.
This strategic move was driven by the principles enshrined in Article 37 of Part IV of the Indian
Constitution, which delineates the Directive Principles of State Policy (DPSP).

Directive Principles of State Policy (DPSP)

Article 37 of the DPSP sets the foundation for many progressive changes in India's economic and
social landscape. Although these principles are not enforceable by any court, they are deemed
fundamental to the country's governance. The government, as per the Indian Constitution, is
duty-bound to apply these principles when formulating policies and laws related to various
sectors, including electricity, insurance, and oil. It is within this constitutional framework that the
path to nationalization of major industries, including banking, was charted.

Socialism and the Promotion of Banking Facilities

The Indian Constitution incorporates the term 'Socialist' within its ambit, as reflected in the
DPSP. This inclusion underscores the government's commitment to social and economic justice,
emphasizing the need for equitable wealth distribution and the eradication of poverty. In line
with these principles, the government recognized that after gaining independence, widespread
access to banking facilities remained a distant dream for a significant portion of the Indian
population. It was imperative to address this issue and promote the spread of banking services to
all corners of the nation.

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Nationalization: A Means to Promote Banking Access

In the early post-independence era, banking facilities were concentrated in urban areas and large
cities, leaving vast swathes of the rural population without access to financial services. This
imbalance was perpetuated by moneylenders who often charged exorbitant interest rates,
disproportionately affecting the economically disadvantaged. To counter this, the government
initiated a series of reformative steps, one of which was the nationalization of banks.

Nationalization was not limited to the banking sector alone; it encompassed other critical
industries, including insurance companies, oil refineries, and electrical companies. The
overarching motive was to ensure that the benefits of banking and financial services reached
every nook and cranny of India. The public was educated about the advantages of banking over
moneylenders, emphasizing the safety of deposits and lower interest rates offered by banks.
Nationalization was, therefore, a means to break the misconception that banks catered
exclusively to the wealthy elite.

Addressing the Risk of Financial Control and Prioritizing Key Sectors

By 1969, the Indian banking landscape was dominated by 14 commercial banks that collectively
held a mere 5% of the total deposits. These banks had substantial minimum deposits, such as 50
crores, which effectively excluded small depositors and prioritized the interests of the affluent.
This concentration of financial power posed significant risks, including the potential for undue
influence by the private sector. Additionally, rural, agricultural, and small or medium-scale
industries were marginalized and neglected by these banks, perpetuating economic disparities.

The move towards nationalization was a strategic response to these challenges. By bringing
banks under government control, the state could not only ensure equitable access to banking
services but also direct credit toward sectors that were crucial for India's economic development,
such as agriculture, rural areas, and small-scale industries. This step served as a corrective
measure to align the banking sector with the broader principles of social and economic justice
enshrined in the Indian Constitution.

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The State Bank of India Act of 1955 and the subsequent nationalization of banks were critical
steps in India's journey towards achieving equitable access to banking facilities, economic
development, and social justice. These policies were firmly rooted in the principles of the Indian
Constitution, particularly the DPSP, which mandated the government to apply these principles in
its policy and legislative actions. Nationalization of banks not only expanded banking services
across the nation but also ensured that the financial system was geared toward serving the
broader interests of society, including rural and economically marginalized sections. In essence,
it was a pivotal moment that helped reshape India's financial landscape and advance the cause of
economic and social equality.

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Bank Nationalization in India: The Legislative and Constitutional
Context

The nationalization of banks in India in 1969 was a watershed moment in the country's economic
history. On July 19, 1969, the President of India, under the authority granted by Article 123(1) of
the Indian Constitution, promulgated the "Banking Companies (Acquisition and Transfer of
Undertakings) Ordinance, 1969," thereby setting the stage for the nationalization of 14 major
banks. This ordinance played a crucial role in the transformation of the Indian banking sector,
although it also gave rise to important constitutional and legal questions.

The Banking Companies (Acquisition and Transfer of Undertakings) Ordinance, 1969

The ordinance was introduced under Article 123 of the Indian Constitution, which grants the
President the authority to promulgate ordinances in cases where immediate legislative action is
required, and both Houses of Parliament are not in session. Article 123(1) states, "If at any time,
except when both Houses of Parliament are in session, the President is satisfied that
circumstances exist which render it necessary for him to take immediate action, he may
promulgate such Ordinance as the circumstances appear to him to require."

Under the authority of this constitutional provision, the government introduced the Banking
Companies (Acquisition and Transfer of Undertakings) Ordinance, 1969. This ordinance laid the
groundwork for the nationalization of banks in India, which aimed to promote the equitable
distribution of banking services and resources, particularly in underserved rural and semi-urban
areas. The nationalization policy sought to address issues like excessive concentration of
economic power and high interest rates charged by private moneylenders.

The Role of R.C. Cooper and the Petition

It is noteworthy that two of the banks among the 14 that were nationalized, namely the Central
Bank of India and the Bank of Baroda, had R.C. Cooper as a shareholder. R.C. Cooper, the

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petitioner in the famous "Bank Nationalization Case," brought this matter to the forefront,
challenging the government's actions.

One of the key issues raised in the case was the timing of the promulgation of the ordinance. The
parliamentary session was scheduled to commence just two days after the ordinance was enacted.
Cooper questioned the necessity of resorting to an ordinance rather than introducing the
nationalization policy as a bill in the upcoming parliamentary session. This raised questions
about whether there was indeed an urgent need for immediate action under Article 123 or
whether the ordinance was a means to circumvent the parliamentary process.

The Role of Acting President V.V. Giri

During this crucial period, V.V. Giri, an eminent figure in Indian politics, held the office of
acting President. Giri, who had previously served as Chief Justice of India and Vice-President of
India, was set to relinquish his duties on July 20, 1969. Notably, the ordinance was promulgated
on July 19, 1969, a Saturday, just before the commencement of the monsoon session of the Lok
Sabha on July 21, 1969.

R.C. Cooper and other critics of the government's actions questioned whether the circumstances
warranted the use of Article 123, given that the parliamentary session was imminent and the
urgency for immediate action was unclear. V.V. Giri's role in approving the ordinance under
these circumstances came under scrutiny.

The nationalization of banks in 1969 and the subsequent legal challenges, exemplified by the
"Bank Nationalization Case" initiated by R.C. Cooper, remain an integral part of India's legal
and constitutional history. This period exemplifies the intersection of constitutional provisions,
legislative actions, and the dynamics of the executive branch. The use of Article 123 to
promulgate the ordinance raises important questions about the interpretation of constitutional
powers and their application in times of transformational policy change.

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The case also underscores the judiciary's role in upholding the principles of constitutional
governance and ensuring transparency and accountability in the decision-making process.
Regardless of the outcomes of the legal battle, the events surrounding the nationalization of
banks continue to be of historical and legal significance, shaping India's approach to economic
and social policies.

R.C. Cooper v. Union of India: A Pioneering Landmark in Indian

Constitutional Law

The case of R.C. Cooper vs. Union of India, popularly known as the "Bank Nationalization
Case," is a cornerstone in the history of Indian constitutional law. Filed by R.C. Cooper, a
shareholder of the Central Bank of India and the Bank of Baroda, this case addressed multiple
pressing issues, leading to a landmark judgment with far-reaching implications for Indian
jurisprudence. Below, we delve into the intricate details of the case and its profound impact on
the legal and constitutional landscape.

Issues Addressed in the Case:

The R.C. Cooper case tackled several key issues:

1. Shareholder's Right to File a Petition on Behalf of the Company: The primary issue raised was
whether a shareholder could file a petition on behalf of a company. R.C. Cooper contended that,
while a company does not possess fundamental rights, his rights as a shareholder were violated
due to the government's nationalization ordinance. The respondent argued that, according to the
Indian Constitution and the Indian Citizenship Act of 1955, a company is a juristic entity and
cannot claim fundamental rights. The Supreme Court held that neither directors nor shareholders
can assert their fundamental rights on behalf of a company under Article 32 or 226 of the
Constitution.

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2. Validity of the Ordinance's Promulgation: The case also examined whether the promulgation
of the ordinance was proper. The Supreme Court asserted that the government holds subjective
power to issue ordinances, and the timing of the promulgation was a matter beyond judicial
interference.

3. Validity of Schedule II of the Ordinance: A contentious point in the ordinance was Schedule
II, which outlined the compensation process for shareholders in case of a bank's acquisition. The
Supreme Court found the provision stipulating compensation after ten years, following a
tribunal's verdict, to be illogical and baseless.

4. Violation of Fundamental Rights (Articles 19(1), 13, and 31(2)): The government argued that
it was not infringing on any fundamental rights and had the authority to create a monopoly for
the greater public welfare. However, the Supreme Court determined that Article 31(2) had been
breached by the government through Schedule II of the Act. This judgment led to the
introduction of the 25th Amendment in 1971 to rectify the situation.

The Court also found a violation of Article 14 (Right to Equality) since only 14 banks were
nationalized, while other banks, including foreign ones, continued to operate privately.

Key Principles Laid Down by the Verdict:

The judgment in the R.C. Cooper case established two fundamental principles:

1. Restriction on Shareholders and Directors: It affirmed that no shareholder or director can

assert fundamental rights on behalf of a company unless their individual rights are directly
affected.

2. The "Effect Test": The Court introduced the "Effect Test," a doctrine first articulated by K.
Gopalan. According to this concept, the validity of an ordinance should be evaluated based on its
effects, rather than its motives or objectives.

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Post-Developments:

Subsequent to the judgment, the government secured a majority in both the Lok Sabha and Rajya
Sabha in the following election. In response to the limitations imposed by the judgment, the
government passed the Banking Companies (Acquisition and Transfer of Undertaking) Act,
1970. Additionally, the Constitution (Twenty-fifth Amendment) Act, 1971 was enacted to
address the restrictions imposed by the judgment.

This amendment empowered the government to acquire private property for public use, with
compensation determined by the Parliament rather than the courts. Furthermore, it exempted
laws implementing Article 39(b) and (c) of the Directive Principles of State Policy from judicial
review, even if they violated fundamental rights.

In conclusion, the R.C. Cooper case is a watershed moment in Indian constitutional law,
reshaping legal and constitutional principles. It exemplifies the intricate interplay of legal
interpretations, constitutional provisions, and executive actions. This landmark case continues to
influence the legal landscape in India, reflecting the judiciary's role in upholding constitutional
principles and ensuring accountability and transparency in government decisions.

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Viewpoint | The nationalization of banks in 1969 had adverse
consequences for India rather than benefiting the country.

The Tumultuous Era of Bank Nationalization in India: An In-depth Examination

The year 1969 marked a significant turning point in the Indian financial sector as the
government, led by Prime Minister Indira Gandhi, embarked on a bold move to nationalize the
14 largest commercial banks in India on July 20, 1969. The implications of this decision,
examined through the lens of history, revealed profound consequences for India's economic
landscape. The official history of the Reserve Bank of India's second volume described this
action as the most pivotal economic policy decision taken by any Indian government post-
independence. In terms of its impact, it overshadowed even the economic reforms of 1991,
which is remarkable in itself. However, understanding this landmark decision requires delving
into the broader context of the times.

The Troubled Decade of the 1960s: A Prelude to Nationalization

The backdrop against which bank nationalization took place was one of immense challenge.
India had faced two wars in the decade—first with China in 1962 and then with Pakistan in
1965—which exerted tremendous pressure on public finances. Further compounding these
difficulties were two consecutive years of drought, resulting not only in food shortages but also
in national security concerns as India had to depend on American food aid to mitigate hunger.
The decision to implement a three-year plan holiday to achieve fiscal retrenchment had also
contributed to a slump in aggregate demand due to the reduction in public investment. The 1966
devaluation of the rupee, while an economic success, had stoked considerable political
resentment. The Congress party, which had already suffered setbacks in the 1967 elections, was
heading for a division. Meanwhile, the Naxalite movement was gaining momentum. Amid these
challenges, Indira Gandhi's government opted for the path of bank nationalization.

Impact of Bank Nationalization: A Three-Pronged Analysis

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The impact of bank nationalization can be dissected into three core areas: deposits, lending, and
interest rates.

1. Deposit Mobilization: A notable positive outcome of bank nationalization was the increase in
financial savings. This was achieved as banks extended their reach by opening branches in
previously unbanked areas. Gross domestic savings surged, nearly doubling as a percentage of
national income during the 1970s. A significant portion of these savings was absorbed by the
government through the increase in the statutory liquidity ratio.

2. Credit Planning and Interest Rates: Credit planning introduced a complex interest rate
structure, with different rates for various loan categories. The Indian central bank found itself
managing a multitude of interest rates. This intricate structure persisted until the 1991 economic
reforms when the central bank began to manage the pivotal repo rate, allowing commercial
lending rates to be determined by banks themselves.

3. Political Control Over Lending: Despite assurances to the contrary, political influence over
bank lending remained pervasive. This control extended well into the post-1991 reform era and
contributed to the problematic issue of non-performing loans that has weighed on the Indian
economy since 2012. Successive governments have maintained a tight grip on the banking
sector, underscoring the political importance of controlling the credit flow in the economy.

The Broader Political and Economic Context: A Lost Decade

Bank nationalization was not an isolated policy decision but rather a pivotal element in a broader
political economy strategy adopted during the 1970s, a decade in which economic growth
marginally outpaced population growth. Average incomes stagnated, making it a lost decade for
India. While exogenous factors such as rising energy prices and failed monsoons contributed to
this stagnation, economic policies also played a role. Bank nationalization did yield positive
results in terms of financial inclusion due to the rapid proliferation of bank branches.

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Nevertheless, its long-term effects, especially the political interference in credit allocation,
ultimately did more harm than good.

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Conclusion

In conclusion, the bank nationalization policy of 1969 in India remains a subject of significant
historical and economic importance. The decision to nationalize 14 major commercial banks
under the leadership of Prime Minister Indira Gandhi marked a turning point in India's financial
landscape. Several key factors and repercussions have emerged from our discussion today:

The decision for bank nationalization occurred in the midst of a turbulent decade marked by
wars, droughts, and political upheaval. These challenges presented a backdrop against which the
nationalization was framed as a response to complex economic and political difficulties. A
noteworthy consequence of bank nationalization was the expansion of financial savings. The
spread of bank branches to previously unbanked areas led to a surge in gross domestic savings
during the 1970s. A significant portion of these savings was funneled into government coffers
through the statutory liquidity ratio. Credit planning introduced an intricate interest rate structure,
creating a labyrinth of rates for various types of loans. This intricate system posed a considerable
challenge to the Indian central bank until it was streamlined following the economic reforms of
1991. Despite assurances of autonomy, political interference in lending practices remained a
persistent issue. This influence extended well into the post-1991 reform era and contributed to
the non-performing loan crisis that has burdened the Indian economy since 2012. Bank
nationalization was not just an isolated policy decision; it was a fundamental component of a
broader political economy strategy adopted in the 1970s. This was a decade when economic
growth barely outpaced population growth, leading to stagnant average incomes and making it a
"lost decade" for India. The impact of bank nationalization in India continues to be a subject of
debate and reflection. While it achieved certain goals, such as financial deepening and expanded
access to banking services, it also carried long-term consequences, including the enduring
influence of the government in banking and credit allocation.

In sum, India's bank nationalization was a pivotal moment in the nation's economic history,
marking a transition towards a more controlled and regulated financial system. While it was
initiated to address specific economic and political challenges, it generated both positive and
negative consequences that continue to shape India's economic landscape. The nuanced nature of

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this policy, intertwined with historical and political contexts, underscores its enduring
significance in the Indian economic narrative.

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Citations
[1] Rustom Cavasjee Cooper V. Union of India [1970] AIR 564, [1970] SCR(3) 530
[2] The Bank Nationalisation Case, A Turning Point in the Interpretation of Fundamental Rights,
Juris Edge (Aug. 14, 2021, 7:35 PM), http://www.jurisedge.com/wp-
content/uploads/RC%20Cooper%20Presentation.pdf
[3] The Banking Companies (Acquisition and Transfer of Undertakings) Ordinance, 1969
[4] Hemant Varshney, R.C. Cooper Vs. Union of India- Bank Nationalisation Case- Case
Summary, Law Times Journal (Aug. 15, 2021, 3:41 PM), http://lawtimesjournal.in/r-c-cooper-v-
union-of-india-bank-nationalization-case-case-summary/
[5] The Indian Citizenship Act, 1955
[6] Gautam Bhatia, The Andhra Pradesh Ordinances Case – Towards Substantive Judicial
Review, Indian Constitutional Law and Philosophy (Aug. 15, 2021, 6:34 PM),
https://indconlawphil.wordpress.com/tag/effect-based-test/
[7] Banking Companies (Acquisition and Transfer of Undertaking) Act, 1970
[8] The Constitution (Twenty-fifth Amendment) Act, 1971
[9] Kesavananda Bharati Sripadagalvaru & Ors. v. State of Kerala & Anr., [1973] 4 SCC 225;
AIR [1973] SC 1461
[10] Austin & Granville, Working a Democratic Constitution – A History of the Indian
Experience, 258–277 (New Delhi: Oxford University Press)
[11] Ramakumar, R. “Economic Milestone and a Poignant Anniversary.” The Hindu, 8 Aug.
2019, www.thehindu.com/opinion/lead/economic-milestone-and-a-poignant-
anniversary/article28917223.ece.
[12] Rajadhyaksha, Niranjan. “Opinion: The 1969 Bank Nationalization Did India More Harm
than Good.” Mint, 16 July 2019, www.livemint.com/opinion/columns/opinion-the-1969-bank-
nationalization-did-india-more-harm-than-good-1563295097940.html.

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