Rajasthan State Electricity Board v. Mohan Lal & Others (1967)

Quick Summary

The case explains when a statutory body counts as “State” under Article 12. The Supreme Court said that “other authorities” covers bodies like the Rajasthan State Electricity Board because the law gives them public powers. Even if they do commercial work, they still fall under the Constitution and must follow Articles 14 and 16.

• Core idea: Legal power from statute → “Authority” → Part of “State”.
• Result: Promotion decisions must respect equality and fairness.

Issues

1. Does the Rajasthan State Electricity Board fall within “other authorities” under Article 12?
2. If yes, must its promotion actions satisfy Articles 14 and 16?

Rules

Article 12: “The State” includes Government and other authorities within India.

The Court held: authorities in Article 12 include constitutional or statutory bodies on whom law confers powers. Commercial activity does not exclude Article 12 status.

Arguments

The Supreme Court upheld that “other authorities” in Article 12 includes constitutional or statutory bodies with powers granted by law. Commercial work does not remove Article 12 status.

Therefore, the Board falls within “State,” and its promotion decisions must follow equality guarantees under Articles 14 and 16.

Ratio Decidendi

If a body is created by statute and holds legal power to act for public purposes, it is an “authority” under Article 12. The nature of its function (even trade or business) does not change this status.

Why It Matters

• Sets a broad and practical test for Article 12.
• Keeps statutory bodies answerable to equality and fairness.
• Supports public accountability even when bodies do commercial work.

Key Takeaways

• Statute + Public Power = Authority.
• Commercial work ≠ Exit from Article 12.
• Equality rules apply to promotions and service matters.

Mnemonic + 3-Step Hook

Mnemonic: “SPA: Statute–Power–Accountable”

1. Statute creates the body.
2. Power is legal and public in nature.
3. Accountable under Articles 14 & 16.

IRAC Outline

Issue: Is the Board an “authority” under Article 12?

Rule: Statutory bodies with conferred powers are “authorities,” even if engaged in trade.

Application: The Board was created by law and exercised public powers; equality norms apply.

Conclusion: The Board is “State.” Its promotion decisions must meet Articles 14 & 16.

Glossary

Article 12

Defines “State” for Part III rights.

Authority

A body with legal power given by statute.

Deputation

Temporary service in another department/body.

FAQs

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