Sukhdev Singh v Bhagatram (1975) | Is a Public Corporation the State? Article 12 | Part 2

When the government works through a corporation, do the same constitutional duties still apply? Sukhdev Singh v. Bhagatram Sardar Singh Raghuvanshi (1975) explained in simple English - Articles 12, 14 and 16. Part 2 of 40 in Law Easy's Constitutional Case Laws series for LL.B., CLAT PG, UGC NET Law and judiciary preparation. THE FACTS The dispute involved employees of statutory corporations - the Oil and Natural Gas Commission, the Life Insurance Corporation and the Industrial Finance Corporation. The questions were whether these employees could claim constitutional protection in service matters, or whether the corporations were just employers like private companies. THE LEGAL QUESTION Are statutory corporations 'authorities' under Article 12, and can their employees enforce service regulations as more than an ordinary private contract? WHAT THE SUPREME COURT HELD The Supreme Court held that these statutory corporations were authorities covered by Article 12. They were created by laws passed by the legislature, and their powers and service regulations came from those laws. When a binding statutory regulation is violated in removing an employee, it cannot be treated as an ordinary private contract dispute. Justice K. K. Mathew's opinion asked whether a body works as an agency or instrumentality of the government. KEY POINTS TO REMEMBER - 'Instrumentality' means an organisation through which the government carries out its work - The government cannot escape constitutional duties by using a corporation instead of a department - Not every company becomes the State merely because the government regulates it FOR YOUR EXAM Link this case with Rajasthan SEB v Mohan Lal and Ajay Hasia to explain how Article 12 developed. The key idea for answers: statutory corporations can be bound by fundamental right duties. CONTINUE THE SERIES Next, Part 3: Ajay Hasia v Khalid Mujib Sehravardi | Article 12 Instrumentality of State Test https://youtu.be/hSVBZSm4o0g Related, Part 1: Rajasthan State Electricity Board v Mohan Lal (1967) | Article 12 Explained https://youtu.be/mFh14vAaFYQ 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=121 (this case starts at 2:01) 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