Rajasthan State Electricity Board v Mohan Lal and Ors.

Facts

• Employees of the Rajasthan State Electricity Board sought to enforce certain rights against the Board by way of a writ petition, requiring them to establish that the Board was "State" within Article 12
• The Board contended it was a separate statutory body, not the "State," and therefore not amenable to writ jurisdiction for fundamental rights enforcement

Issue

1. Whether a statutory corporation, such as the Rajasthan State Electricity Board, constituted under an Act of Parliament or state legislature, falls within the meaning of "State" under Article 12.

Held

• "Other authorities" within Article 12 includes bodies that are created by statute and are invested with the power to make rules and regulations having the force of law
• The Rajasthan State Electricity Board, having been created by statute and vested with regulation-making power, was held to be an "authority" within Article 12
• This significantly expanded the scope of "State" beyond traditionally understood government departments and local self-government bodies

Ratio Decidendi

A statutory body constituted under an Act of the legislature, possessing power to issue binding rules and regulations akin to law, qualifies as "other authority" and therefore "State" under Article 12, making it amenable to writ jurisdiction for enforcement of fundamental rights.