2026 Supreme(SC) 240

SUPREME COURT OF INDIA
Vikram Nath, Sandeep Mehta, JJ.
Anurag Krishna Sinha – Appellant
Versus
State Of Bihar & Anr. – Respondents
Civil Appeal No. 13581 of 2025
Decided On : 10-03-2026

IMPORTANT POINTS
(1) Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is declared unconstitutional and accordingly struck down – Mere passage of time does not supply any justification.
(2) Public Trust – Fact that an institution is intended to serve a public purpose or is open to public use does not, by itself, conclusively determine that trust is a public trust in law – Legal character of a trust depends on several factors.
(3) Equality before law is not a mere formal concept; it embodies principle that State action, whether legislative or executive, must be based on rational criteria and must not operate in an arbitrary or capricious manner.

Headnote:

(A) Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 – Section 4(2) – Constitution of India – Article 300A read with Article 14 – Validity of – impugned Act discloses multiple features of manifest arbitrariness – While stated object of Act is “better management and development” of Institute & Library, means adopted by the legislature bear no rational or proportionate nexus to that object – In absence of demonstrated necessity, compulsory acquisition coupled with dissolution of trust arrangements is plainly disproportionate – A law which proceeds on unreasoned assumptions, adopts excessive means, or operates without adequate determining principles equally attracts constitutional censure – Impugned Act, by extinguishing long-standing rights and arrangements without cogent justification, departs from discipline of reason that Article 14 mandate – A statutory provision that enables acquisition of property while reducing compensation to a token amount lacks basic attributes of fairness – Confiscatory nature of vesting contemplated under impugned Act reinforces conclusion that enactment is manifestly arbitrary and fails constitutional scrutiny – Mere passage of time does not supply any justification – When legislature re-enacts substantially same measure that has previously failed, without placing any new or cogent material before Court to justify the same, legislative history becomes a relevant consideration – Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is declared unconstitutional and accordingly struck down. (Paras 37, 39, 43, 45, 46, 50, 51, 52, 53 and 54)

(B) Indian Trusts Act, 1882 – Section 3 – Public Trust – Fact that an institution is intended to serve a public purpose or is open to public use does not, by itself, conclusively determine that trust is a public trust in law – Legal character of a trust depends on several factors, including manner in which dedication is made, structure of trust, nature of control and management, and rights reserved by Settlor and his successors under trust deed – A public facing object, standing alone, is not determinative – Even if it were assumed that Trust has a public character, that fact alone does not legitimise State’s action in acquiring Institute & Library or dissolving existing trust arrangements – Whether Trust is public or private, any legislative measure resulting in compulsory acquisition and vesting must satisfy constitutional requirements, particularly those flowing from Article 14. (Paras 19 and 22)

(C) Constitution of India – Article 14 – Equality before law – Equality before law is not a mere formal concept; it embodies principle that State action, whether legislative or executive, must be based on rational criteria and must not operate in an arbitrary or capricious manner – Arbitrariness is fundamentally incompatible with constitutional governance, as it replaces reasoned decision-making with uncertainty and unfettered discretion – Where clear and substantive unreasonableness is embedded in a legislative enactment, Court is not only empowered but obliged to intervene – Manifest arbitrariness is a ground available to this Court to strike down legislation under judicial review of Article 14 – Arbitrariness, in whatever form it manifests, whether in conferral of uncanalised power, adoption of excessive means, absence of rational nexus, or imposition of consequences wholly disproportionate to stated object, is antithetical to constitutional guarantee of equality and invites intervention of this Court – A law which departs from these requirements attracts vice of manifest arbitrariness and is liable to be struck down as violative of Article 14. (Paras 23, 24, 35 and 36)

Facts of the case:

Present appeal challenges final judgment and order dated 29th February 2024 passed by High Court of Judicature at Patna in Civil Writ Jurisdiction Case No.7940 of 2015 whereby appellant’s writ petition has been dismissed by High Court while upholding validity of Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015.

Findings of Court:

Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is manifestly arbitrary and violative of Article 14 of Constitution of India.

Result : Appeal allowed.