State of Karnataka v. Union of India (1977)

CASE_TITLE: State of Karnataka v. Union of India (AIR 1977 SC 69)

In this case, the State sued the Union in the Supreme Court under Article 131. The dispute was about a Union-appointed Inquiry Commission into alleged misconduct of the Chief Minister, even though the State had already set up its own commission. The Court held that the suit is maintainable under Article 131, that both commissions can run because their aims differ, and that Section 3 of the Commissions of Inquiry Act, 1952 is valid.

1. Is the suit between the State and the Union maintainable under Article 131?
2. Is the Union’s notification appointing a Commission under Section 3 of the Commissions of Inquiry Act, 1952 ultra vires?
3. If within Section 3, is Section 3 itself unconstitutional?

Article 131 gives the Supreme Court original jurisdiction over disputes involving a legal right, when the parties are: (a) the Union and one or more States, (b) States inter se, or (c) a State and another State’s government. A dispute must raise a real question of law or fact about a legal right.

Section 3, Commissions of Inquiry Act, 1952 lets the government appoint a Commission to inquire into matters of public importance.

The Supreme Court held:

• Maintainability: The suit is maintainable under Article 131. The State and the Union are separate constitutional persons. The dispute involved the State’s legal right.
• Dual Commissions: The Union and the State may run separate commissions because their notifications had different aims and scopes. Overlap of facts is not fatal.
• Section 3 Validity: Section 3 of the Commissions of Inquiry Act, 1952 is constitutional. The principle of collective responsibility is not undermined when the issue concerns alleged misconduct, not proper official action.

Article 131 covers disputes of legal right between the Union and a State. A State may sue to defend its institutional authority, including in matters tied to actions of its Ministers acting in official capacity. Section 3 empowers both levels of government to inquire into public matters; distinct purposes allow parallel inquiries. The doctrine of collective responsibility does not shield alleged personal misconduct.

• Federal clarity: Confirms separate legal identity of State and Union.
• Door to Supreme Court: Shows when Article 131 suits are viable.
• Inquiry powers: Validates Union’s use of s.3 even alongside a State inquiry.
• Accountability: Keeps collective responsibility intact while allowing probes into alleged misconduct.

1. Suit maintainable under Article 131 where a State’s legal right is at stake.
2. Dual commissions are fine if objectives differ.
3. Section 3 of the Commissions of Inquiry Act is constitutional.
4. Collective responsibility is not a shield for alleged misconduct.

Mnemonic: “MAD C” — Maintainability (A131), Different aims (dual commissions), Section 3 (valid), Collective responsibility (not engaged).

1. Spot the A131 dispute of legal right.
2. Split the inquiries by purpose.
3. State that s.3 is valid; collective responsibility not in issue.

Issue: A131 maintainability; validity and scope of Union’s s.3 notification; constitutionality of s.3.

Rule: A131—original jurisdiction over disputes of legal right between Union/States; s.3—power to appoint inquiry commissions.

Application: State and Union are separate entities; dispute concerns State’s legal authority; inquiries differ in aim; s.3 aligns with Constitution and does not hit collective responsibility.

Conclusion: Suit maintainable; dual commissions permissible; s.3 valid.

Article 131

Supreme Court’s original jurisdiction in Union–State and inter-State disputes about legal rights.

Ultra vires

Beyond legal power or authority.

Commissions of Inquiry Act, 1952 — s.3

Allows government to appoint a commission on public importance matters.

Collective responsibility

Cabinet principle: Ministers share responsibility for decisions taken as a government.

Reviewed by The Law Easy.