Rajasthan State Electricity Board v Mohan Lal (1967) | Article 12 Explained | Part 1

Can a public electricity board ignore the Constitution just because it sells electricity? Rajasthan State Electricity Board v. Mohan Lal (1967) explained in simple English - Articles 12, 14 and 16. Part 1 of 40 in Law Easy's Constitutional Case Laws series for LL.B., CLAT PG, UGC NET Law and judiciary preparation. THE FACTS Mohan Lal, a government employee whose services were placed with the Rajasthan State Electricity Board, complained that other employees were promoted while he was unfairly left out. He relied on Articles 14 and 16. The Board answered that it was not 'the State' under Article 12 because supplying electricity is a commercial activity. THE LEGAL QUESTION Is a statutory electricity board an 'other authority' under Article 12, so that Articles 14 and 16 apply to it? WHAT THE SUPREME COURT HELD Yes. The Supreme Court rejected the Board's argument. The words 'other authorities' in Article 12 are not limited to bodies that look like the government departments named there. An authority created by a statute and given legal powers can fall within Article 12, and selling electricity did not make the Board a private body. KEY POINTS TO REMEMBER - 'Other authorities' in Article 12 has a wide meaning - The name of the body is not decisive - its legal character and statutory powers are - An early and important step in the growth of Article 12, developed later in Sukhdev Singh and Ajay Hasia FOR YOUR EXAM This is the starting point of the Article 12 chain: Mohan Lal, Sukhdev Singh, Ajay Hasia, Pradeep Kumar Biswas. Remember the conclusion: a statutory electricity board can be the State under Article 12. CONTINUE THE SERIES Next, Part 2: Sukhdev Singh v Bhagatram (1975) | Is a Public Corporation the State? Article 12 https://youtu.be/DjhNZI82ChA Related, Part 3: Ajay Hasia v Khalid Mujib Sehravardi | Article 12 Instrumentality of State Test https://youtu.be/hSVBZSm4o0g 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=0 (this case starts at 0:00) 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