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Supreme Court of India10 March 20262026 INSC 219

Anurag Krishna Sinha v. State of Bihar

Bench of 2 · Justice Vikram Nath, Justice Sandeep Mehta

Why it matters

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Advocates challenging State legislation that acquires or dissolves trust or private institutions can cite this judgment for the proposition that "better management" as a preamble object does not justify the most extreme legislative measure when less invasive alternatives (grant-in-aid, conditional funding, statutory audit, supervisory oversight) are available; the absence of any pre-enactment inquiry or notice to the affected institution is itself a powerful indicator of manifest arbitrariness under Article 14. The judgment also settles that a token or illusory compensation provision independently renders an acquisition law confiscatory and unconstitutional under Article 300A.

Summary

The appellant — great-grandson of the Settlor and serving Trustee of the Smt. Radhika Sinha Institute and Sachchidanand Sinha Library, a century-old institution established in 1924 — challenged the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 by way of a writ petition before the Patna High Court. The High Court dismissed the petition and upheld the Act, characterising the Trust as a public trust and holding the takeover to be in furtherance of the Trust's objects. The appellant appealed to the Supreme Court.

The Supreme Court allowed the appeal and struck down the 2015 Act as unconstitutional. The Court held the Act manifestly arbitrary and violative of Article 14 on multiple, cumulative grounds: (i) the State effected a complete vesting of the Institute & Library under Section 3 and simultaneously dissolved the Deed of Trust, the Agreement, the Lease and all committees under Section 4(2), without any prior inquiry, finding of mismanagement, or demonstrated necessity; (ii) examination of the original State records revealed not a single communication to the Trust alleging mismanagement or financial irregularity before the Act was passed; (iii) the State's own appointee — the State Librarian functioning as ex-officio Chief Librarian — bore supervisory responsibility for day-to-day administration, yet no action was ever taken against him; (iv) the compensation provision in Section 7, capping payment at a maximum of one rupee, was illusory and confiscatory, failing the standard that law depriving property under Article 300A must be just, fair and reasonable; and (v) the Act replicated the failed 1983 Ordinance without any fresh material justifying acquisition.

The Court rejected the High Court's characterisation of the Trust as a public trust, holding that a public-facing object alone is not determinative of a trust's legal character — the structure, control, management, and rights reserved by the Settlor under the deed are equally material. The Court also noted that neither party had pleaded or argued the public-trust point before the High Court, making it impermissible for the High Court to decide the case on that basis. Relying on the line of authority from E.P. Royappa v. State of Tamil Nadu through Shayara Bano v. Union of India and Association for Democratic Reforms v. Union of India, the Court reaffirmed that manifest arbitrariness — including excessive means, absence of rational nexus, and disproportionate consequences — is a firm substantive ground to strike down legislation under Article 14. The Trust's management and administration were directed to be restored to their pre-enactment position, without prejudice to the State providing financial assistance or regulatory oversight in accordance with law.

Key principle

A State legislation that compulsorily acquires and dissolves a long-standing trust without any prior inquiry, demonstrated necessity, or finding of mismanagement, and provides only illusory compensation capped at one rupee, is manifestly arbitrary and violates Article 14; Article 300A further requires that any law depriving a person of property must be just, fair, reasonable and non-confiscatory. The legal character of a trust — public or private — turns on the structure of the deed, the nature of control, and the rights reserved by the Settlor, and is not determined solely by the public-facing purpose of the institution.

Holding

Allowed — the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is struck down as manifestly arbitrary and violative of Article 14 read with Article 300A of the Constitution, because it effected a total legislative takeover of a century-old trust institution without any prior inquiry, demonstrated mismanagement, or meaningful compensation framework.

Statutes invoked

  • Constitution · Article 14
  • Constitution · Article 300A
  • Constitution · Article 254(1)
  • Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 · Section 3
  • Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 · Section 4(2)
  • Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 · Section 7
  • Trust Act · Section 3

Practice areas

constitutionalpropertywrit
AI-generated summary, written by Claude Sonnet 4.6 from the court's published judgment. Always verify the original before relying on the summary in court. Generated on 21 May 2026.