State of West Bengal v. Union of India

Quick Summary

The Supreme Court held that Parliament can make laws to acquire property owned by a State. In India, States are not sovereign outside the Constitution. The dispute fell under Article 131, so the Supreme Court could hear it directly. The Acquisition and Development Act was held within Parliament’s power, supported by Entry 42, List III (acquisition and requisition).

Issues

• Can Parliament pass a law to buy State-owned land and related rights?
• Do Indian States have any independent sovereign power outside the Constitution?
• Did the Act, or any part of it, go beyond Parliament’s legislative authority?
• Is the plaintiff State entitled to relief?

Rules

• Article 131: Supreme Court has exclusive original jurisdiction over State vs Union legal disputes.
• Entry 42, List III: Acquisition and requisition of property (Concurrent List) allows Parliamentary legislation.
• Articles 32 & 226: Writ jurisdiction for fundamental rights (context to show the Court’s role as rights guardian).

Arguments

Judgment

The Supreme Court upheld the Act. It ruled that Parliament has power to acquire State property under Entry 42, List III. States are not sovereign entities outside the Constitution. When legal rights of a State vis-à-vis the Union are in question, Article 131 allows the Supreme Court to hear the dispute directly.

Ratio Decidendi

• Constitutional Supremacy: All powers—Union and State—come from the Constitution, not outside it.
• Acquisition Power: Parliament may legislate to acquire property, including that of a State, via Entry 42 (Concurrent List).
• Forum: Article 131 is the correct route for State–Union legal disputes about constitutional rights.

Why It Matters

The case explains Indian federalism: it is Constitution-led, not sovereignty-sharing in the classical sense. It also secures a clear dispute-resolution path (Article 131) and confirms the Concurrent List route for acquisition laws that can touch State property.

Key Takeaways

1. Parliament can validly acquire property owned by a State (Entry 42, List III).
2. States have no separate sovereignty outside the Constitution.
3. Article 131 gives the Supreme Court original jurisdiction in State–Union disputes.
4. Acquisition and Development Act sustained; sections not ultra vires.

Mnemonic + 3-Step Hook

Mnemonic: “PAR-STA-131” — PARliament acquires, STAtes not sovereign, 131 jurisdiction.

1. Spot: Property acquisition affecting a State.
2. Source: Entry 42 (Concurrent List) + Constitutional supremacy.
3. Seat: Article 131 in Supreme Court.

IRAC Outline

Issue: Can Parliament acquire State property? Are States sovereign? Is the Act ultra vires?

Rule: Article 131; Entry 42 (List III); Constitutional supremacy.

Application: Parliament’s law falls within Entry 42; States derive power only from the Constitution; dispute fits Article 131.

Conclusion: Act upheld; Parliament’s acquisition power affirmed; Article 131 jurisdiction confirmed.

Glossary

Article 131

Supreme Court’s original jurisdiction for State–Union disputes.

Entry 42, List III

Concurrent List entry for acquisition and requisition of property.

Ultra vires

Beyond the legal power or authority of a body.

Constitutional Supremacy

The Constitution is the highest law; all powers flow from it.

FAQs

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