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CASE ANALYSIS ON
SUKHDEV SINGH V. BHAGATRAM, AIR 1975 SC 1331

LEGAL RESEARCHER CODE – _LF-15311__

SHIRIN RAZDAN

(AMITY UNIVERSITY, DUBAI)

A) ABSTRACT / HEADNOTE

Issue: Bhagat Ram Singh was dismissed by a corporation under statutory laws like the Oil
and Natural Gas Commission Act, 1959.

Action: Bhagat Ram appealed to the High Court, which deemed his dismissal unlawful and
ordered his reinstatement.

Ruling: The corporation, acting as a state function, was considered a state entity. Rules set by
it lacked legal authority.

Significance: The case broadened Article 12's 'State' definition to include statutory
corporations. It affirmed their regulations as legally binding, making their employees state
servants.

Keywords: Sukhdev Singh v. Bhagatram, Article 12, Statutory Corporations, Force of Law,
Servants of Union or State.

B) CASE DETAILS

i) Judgement Cause Title Sukhdev Singh V. Bhagatram, AIR

1975 SC 1331

ii) Case Number NA

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iii) Judgement Date 21 February, 1975

iv) Court Supreme Court of India

v) Quorum A.N. Ray (CJ), Kuttyil Kurien

Mathew, Y.V. Chandrachud, A.
Alagiriswami, A.C. Gupta

vi) Author A.N. Ray

vii) Citation 1975 AIR 1331, 1975, SCR (3) 619,

1975 SCC (1) 421

viii) Legal Provisions Involved The case involved questions of law

under Article 14 and 16 of the
Constitution of India.

C) FACTS OF THE CASE

1. In Sukhdev Singh v. Bhagatram (AIR 1975 SC 1331), Bhagat Ram Singh Raghuvanshi
was dismissed from his position in corporations governed by statutory laws: ONGC, IFC,
and LIC.
2. These entities operated under their respective acts, such as the Oil and Natural Gas
Commission Act, 1959. Bhagat Ram contested his dismissal in the High Court and won,
with the court deeming it unlawful and ordering his reinstatement.
3. Notably, the court declared the corporations to function as state entities, granting a writ of
mandamus to enforce its ruling. Additionally, in 1972, the High Court emphasized that
the regulations formulated by these corporations lacked legal force, particularly those
specified in Clauses (1) & (4) of Regulation 252[1][2][4].

D) INTRODUCTION AND BACKGROUND OF JUDGEMENT

1. The case, headed over by a panel consisting of five justices, including Justices A.N. Ray,
K.K. Mathew, Y.V. Chandrachud, A. Alagirisamy, and A.C. Gupta, focused on the
termination of employee Bhagat Ram Singh Raghuvanshi by a corporation governed by
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legislative statutes, particularly the Oil and Natural Gas Commission Act, 1959; the
Industrial Finance Corporation Act, 1948; and the Life Insurance Corporation Act, 1956.
2. Bhagat Ram filed a civil appeal with the High Court, seeking restitution and
reinstatement. The High Court ruled that his dismissal was unfair and issued a writ of
mandamus to reinstate him. It determined that the corporation functioned as a state entity.

E) LEGAL ISSUES RAISED

1. The case questioned if statutory corporations like ONGC, IFC, and LIC are considered
'State' or 'authority' under Article 12 of the Indian Constitution.
2. It examined whether regulations set by these corporations carry the weight of law.
3. The case addressed whether employees of such corporations are deemed servants of the
Union or State.
4. It also scrutinized the legality of terminating Bhagat Ram Singh Raghuvanshi's
employment by these corporations.

F) PETITIONER/ APPELLANT’S ARGUMENTS

1. The petitioner claimed that his dismissal was unfair and illegal.
2. It was argued by the petitioner that the corporations, namely the Oil and Natural Gas
Commission, Industrial Finance Corporation, and Life Insurance Corporation, performed
governmental functions and thus should be categorized as a 'State' according to Article 12
of the Constitution.
3. The petitioner asserted that the regulations set forth by the corporation carried legal
authority and ought to be upheld as such.

G) RESPONDENT’S ARGUMENTS
1. Concerning the termination's legality, they asserted that Bhagat Ram Singh removal
following the businesses' established procedures.
2. Concerning whether statutory companies should be deemed 'State,' they contended that
these institutions do not qualify as 'State' or 'authority' under Article 12 of the
Constitution
3. Regarding the status of regulations, they argued that the corporation's policies and
procedures lacks legal effect.
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H) RELATED LEGAL PROVISIONS

Article 14 of the Constitution of India: This article guarantees equality before the law and
equal protection of the laws within the territory of India.
Article 16 of the Constitution of India: This article provides for equality of opportunity in
matters of public employment.

I) JUDGEMENT
a. RATIO DECIDENDI

Article 12 of the Constitution designates statutory corporations, such as the Oil and Natural
Gas Commission, the Industrial Finance Corporation, and the Life Insurance Corporation, as
"State" institutions. As a result, the rules they create have the same legal force as laws. If an
employee's termination is in violation of these regulations, they have the ability to assert their
employment status.

J) CONCLUSION & COMMENTS

A seminal ruling in the Indian legal system, Sukhdev Singh v. Bhagatram (AIR 1975 SC
1331) considerably broadened the meaning of "State" under Article 12 of the Constitution to
encompass statutory corporations. The ruling declared that rules issued by statutory
corporations are binding on the Union or the State, and that workers of such corporations are
considered to be their slaves.

K) REFERENCES
a. Important Case Referred

Sabhajit Tewary v. Union of India (1975) 3 SCR 616 is an important legal case that pertains
to the understanding of Article 12 of the Indian Constitution, delineating the concept of
"State."

Important Statute Referred

L)
The court considered whether legal entities fell under the definition of 'State' under Article 12
of the Indian Constitution.
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