Ajay Hasia v Khalid Mujib Sehravardi | Article 12 Instrumentality of State Test | Part 3

A college is run by a registered society - can that society still be treated as the government? Ajay Hasia v. Khalid Mujib Sehravardi (1980) explained in simple English - Articles 12 and 14. Part 3 of 40 in Law Easy's Constitutional Case Laws series for LL.B., CLAT PG, UGC NET Law and judiciary preparation. THE FACTS The case concerned admission to an engineering college in Srinagar that was managed through a registered society. Some applicants challenged the admission process, particularly the way interviews were used to award marks. THE LEGAL QUESTION Can a registered society be examined under the constitutional rules of equality, i.e. is it 'State' under Article 12? WHAT THE SUPREME COURT HELD The Supreme Court said the formal label of an organisation is not enough. A body does not escape Article 12 merely because it is registered as a society instead of being created directly by a statute. The Court treated the college society as an instrumentality of the State and held that admission decisions must meet constitutional standards of fairness and equality. KEY POINTS TO REMEMBER - Look at substance, not just the name on a registration certificate - Indicators: government funding, deep control over management, functions closely connected with government work, a department transferred to the body - These indicators guide the inquiry - they are not a mechanical checklist FOR YOUR EXAM Ajay Hasia is the classic Article 12 test. Remember its limit: a government grant alone does not make every private school or charity the State - see Pradeep Kumar Biswas (Part 4) for the 'deep and pervasive control' clarification. CONTINUE THE SERIES Next, Part 4: Pradeep Kumar Biswas Case (2002) | Article 12 'State' Test Explained https://youtu.be/yrblDTV3BBQ Related, Part 5: Zee Telefilms v Union of India (2005) | Is BCCI the State? Article 12 & 226 https://youtu.be/RKR3I6RP8Xw All 40 Constitutional Case Laws (playlist): https://www.youtube.com/playlist?list=PLT4r9ZZ3tKLM Complete lecture, all 40 cases in one video: https://youtu.be/oUrSfn3wp8s?t=253 (this case starts at 4:13) Notes and study material: https://www.thelaweasy.com Subscribe to Law Easy for more Constitutional Law, LL.B., CLAT PG, UGC NET Law and judiciary lectures: https://www.youtube.com/@LawEasyin?sub_confirmation=1 Educational content only, not legal advice. Always read the original judgment and check the latest law before relying on a case in an answer or in practice. #ConstitutionalLaw #CLATPG #UGCNETLaw #LawEasy #Article12