The Crossbill Team
The Supreme Court of India has struck down a law enacted by the Government of Bihar that sought to take over and nationalise a historic library and research institution in Patna, ruling that the legislation was unconstitutional and violated the guarantee of equality under Article 14.
In its judgement delivered on March 10, the court held that the law represented a clear instance of “manifest arbitrariness” and ordered restoration of the institution’s original trust management.
The court invalidated the Srimati Radhika Sinha Institute and Sachchidananda Sinha Library (Requisition and Management) Act, 2015, which had transferred ownership and management of the institution to the state government. It also directed that the trust governing the institute be reinstated to the position it held before the enactment of the legislation.
A bench comprising Justices Vikram Nath and Sandeep Mehta observed that the Bihar legislature had taken the most drastic step available—complete acquisition and dissolution of the trust—without establishing any evidence of wrongdoing by those managing the institution.
According to the judgement, the legislative record revealed no prior inquiry, no formal notice to trustees and no documented allegations of financial mismanagement or administrative failure before the state decided to acquire the institution. The court noted that the absence of such procedural safeguards pointed to a fundamentally arbitrary exercise of legislative power.
Setting aside the Patna High Court’s February 29, 2024 judgement, the Supreme Court declared the 2015 Act unconstitutional and restored control of the institute to its trustees. At the same time, it clarified that the state government remains free to extend financial support or regulatory oversight to the institution within the framework of law, emphasising that state involvement must respect constitutional limits and established rights.
The institution at the centre of the case has a long historical legacy. It was founded in 1924 by Sachchidanand Sinha in memory of his wife Radhika Sinha. The founder contributed Rs 50,000 from the sale of ancestral property belonging to Radhika Sinha and donated about 10,000 books from his personal collection.
A trust was formally established in 1926, with the Chief Justice of the Patna High Court designated as the ex-officio trustee. The institute continued to function as a research and library institution for more than a century.
The legal challenge was brought by Anurag Krishna Sinha, the great-grandson of Sachchidanand Sinha, who currently serves as trustee, honorary secretary and chief executive officer of the institute.
Under the 2015 legislation, all rights and interests in the institution were vested in the state government through Section 3. At the same time, Section 4(2) dissolved the trust deed, the 1955 agreement with the state government, lease arrangements and all committees associated with the institution. The Act also included a compensation clause under Section 7 allowing the government to pay a maximum of one rupee for the acquisition.
Earlier, the Patna High Court had dismissed the challenge to the law in February 2024 and went a step further by declaring the trust a public trust rather than a private one, even though neither party had raised the issue. The Supreme Court found fault with this reasoning, stating that courts cannot decide cases on grounds not argued by the parties without giving them an opportunity to respond.
However, the apex court said it was unnecessary to determine whether the trust was public or private for deciding the constitutional question before it.
In assessing the validity of the law, the court traced the development of the doctrine of manifest arbitrariness in Indian constitutional jurisprudence. It referred to earlier rulings including S.G. Jaisinghani v Union of India, E.P. Royappa v State of Tamil Nadu, Maneka Gandhi v Union of India, Ajay Hasia v Khalid Mujib and Indian Express Newspapers v Union of India, which shaped the understanding of equality and arbitrariness under Article 14.
The court noted that the doctrine was firmly established by the Constitution Bench ruling in Shayara Bano v Union of India, which held that legislation could be invalidated if it was capricious, irrational or lacked a clear determining principle. It also cited later decisions such as Joseph Shine v Union of India and Association for Democratic Reforms v Union of India as reaffirming this principle.
Applying the doctrine to the present case, the court found several features that demonstrated arbitrariness. It noted that there was no evidence of abandonment or mismanagement that justified the state’s takeover. Alternative measures—such as financial grants, statutory audits or supervisory oversight—were available but had not been considered before the legislature opted for complete acquisition.
The bench also pointed out contradictions in the state’s position. Under the administrative arrangement governing the institution, the State Librarian functioned as ex-officio Chief Librarian responsible for general supervision of the library. Despite claiming mismanagement, the state had neither initiated an inquiry nor taken any action against its own appointee responsible for the administration of the library.
The state government had argued that it had invested over Rs 72 crore in renovating and developing the institution after taking control. The court acknowledged the investment but held that such expenditure could not retrospectively justify the acquisition, noting that the same objective could have been achieved through less intrusive means.
Another factor considered by the court was the legislative history of the dispute. In 1983, Bihar had issued ordinances to acquire the same institution. Those measures were challenged in court, eventually lapsed, and their effect was set aside by the Supreme Court in 1996. The bench observed that the 2015 Act essentially attempted to achieve the same outcome decades later without presenting any new circumstances that justified such action.
The compensation provision of one rupee was also criticised by the court. While Article 300A allows the state to deprive a person of property through law, the court held that such law must still be just, fair and reasonable. A token compensation of one rupee, it said, was effectively confiscatory and further demonstrated the arbitrary nature of the legislation.
Having reached this conclusion, the court found it unnecessary to examine other constitutional arguments raised by the appellant, including questions of legislative competence and possible conflict with the Indian Trusts Act, 1882.
In its judgement delivered on March 10, the court held that the law represented a clear instance of “manifest arbitrariness” and ordered restoration of the institution’s original trust management.
The court invalidated the Srimati Radhika Sinha Institute and Sachchidananda Sinha Library (Requisition and Management) Act, 2015, which had transferred ownership and management of the institution to the state government. It also directed that the trust governing the institute be reinstated to the position it held before the enactment of the legislation.
A bench comprising Justices Vikram Nath and Sandeep Mehta observed that the Bihar legislature had taken the most drastic step available—complete acquisition and dissolution of the trust—without establishing any evidence of wrongdoing by those managing the institution.
According to the judgement, the legislative record revealed no prior inquiry, no formal notice to trustees and no documented allegations of financial mismanagement or administrative failure before the state decided to acquire the institution. The court noted that the absence of such procedural safeguards pointed to a fundamentally arbitrary exercise of legislative power.
Setting aside the Patna High Court’s February 29, 2024 judgement, the Supreme Court declared the 2015 Act unconstitutional and restored control of the institute to its trustees. At the same time, it clarified that the state government remains free to extend financial support or regulatory oversight to the institution within the framework of law, emphasising that state involvement must respect constitutional limits and established rights.
The institution at the centre of the case has a long historical legacy. It was founded in 1924 by Sachchidanand Sinha in memory of his wife Radhika Sinha. The founder contributed Rs 50,000 from the sale of ancestral property belonging to Radhika Sinha and donated about 10,000 books from his personal collection.
A trust was formally established in 1926, with the Chief Justice of the Patna High Court designated as the ex-officio trustee. The institute continued to function as a research and library institution for more than a century.
The legal challenge was brought by Anurag Krishna Sinha, the great-grandson of Sachchidanand Sinha, who currently serves as trustee, honorary secretary and chief executive officer of the institute.
Under the 2015 legislation, all rights and interests in the institution were vested in the state government through Section 3. At the same time, Section 4(2) dissolved the trust deed, the 1955 agreement with the state government, lease arrangements and all committees associated with the institution. The Act also included a compensation clause under Section 7 allowing the government to pay a maximum of one rupee for the acquisition.
Earlier, the Patna High Court had dismissed the challenge to the law in February 2024 and went a step further by declaring the trust a public trust rather than a private one, even though neither party had raised the issue. The Supreme Court found fault with this reasoning, stating that courts cannot decide cases on grounds not argued by the parties without giving them an opportunity to respond.
However, the apex court said it was unnecessary to determine whether the trust was public or private for deciding the constitutional question before it.
In assessing the validity of the law, the court traced the development of the doctrine of manifest arbitrariness in Indian constitutional jurisprudence. It referred to earlier rulings including S.G. Jaisinghani v Union of India, E.P. Royappa v State of Tamil Nadu, Maneka Gandhi v Union of India, Ajay Hasia v Khalid Mujib and Indian Express Newspapers v Union of India, which shaped the understanding of equality and arbitrariness under Article 14.
The court noted that the doctrine was firmly established by the Constitution Bench ruling in Shayara Bano v Union of India, which held that legislation could be invalidated if it was capricious, irrational or lacked a clear determining principle. It also cited later decisions such as Joseph Shine v Union of India and Association for Democratic Reforms v Union of India as reaffirming this principle.
Applying the doctrine to the present case, the court found several features that demonstrated arbitrariness. It noted that there was no evidence of abandonment or mismanagement that justified the state’s takeover. Alternative measures—such as financial grants, statutory audits or supervisory oversight—were available but had not been considered before the legislature opted for complete acquisition.
The bench also pointed out contradictions in the state’s position. Under the administrative arrangement governing the institution, the State Librarian functioned as ex-officio Chief Librarian responsible for general supervision of the library. Despite claiming mismanagement, the state had neither initiated an inquiry nor taken any action against its own appointee responsible for the administration of the library.
The state government had argued that it had invested over Rs 72 crore in renovating and developing the institution after taking control. The court acknowledged the investment but held that such expenditure could not retrospectively justify the acquisition, noting that the same objective could have been achieved through less intrusive means.
Another factor considered by the court was the legislative history of the dispute. In 1983, Bihar had issued ordinances to acquire the same institution. Those measures were challenged in court, eventually lapsed, and their effect was set aside by the Supreme Court in 1996. The bench observed that the 2015 Act essentially attempted to achieve the same outcome decades later without presenting any new circumstances that justified such action.
The compensation provision of one rupee was also criticised by the court. While Article 300A allows the state to deprive a person of property through law, the court held that such law must still be just, fair and reasonable. A token compensation of one rupee, it said, was effectively confiscatory and further demonstrated the arbitrary nature of the legislation.
Having reached this conclusion, the court found it unnecessary to examine other constitutional arguments raised by the appellant, including questions of legislative competence and possible conflict with the Indian Trusts Act, 1882.
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