Anurag Krishna Sinha v. State of Bihar (2026 INSC 219)

Anurag Krishna Sinha v. State of Bihar (2026 INSC 219)

Citation: 2026 INSC 219
Civil Appeal No.: 13581 of 2025
Date of Judgment: March 10, 2026
Bench: Vikram Nath & Sandeep Mehta, JJ.

(1) Facts of the Case

• The Institution: The case concerns the Smt. Radhika Sinha Institute and Sachchidanand Sinha Library, established in 1924 by Shri Sachichidanand Sinha in memory of his wife. It was created as a trust via a formal Deed of Trust in 1926, with the settlor’s family holding the position of Hereditary Trustee and Chief Executive Officer.
• State’s Role: In 1955, an agreement with the Government of Bihar designated it as a State Central Library. The government provided financial assistance, and the State Librarian acted as an ex-officio Chief Librarian, but management remained with the Trustees.
• Previous Attempt: In 1983, the State attempted to take over the trust via ordinances. This was challenged, and this Court ultimately held in 1996 that the lapse of those ordinances rendered all actions thereunder non-est.
• The Impugned Act: In 2015, the Bihar Legislature enacted the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015. The Act provided for the complete vesting of the Institute & Library, along with all rights, title, and interest, in the State Government (Section 3). It also dissolved the Trust Deed, the 1955 Agreement, and all committees (Section 4(2)). Section 7 provided for a maximum compensation of one rupee.
• Procedural History: The appellant, the great-grandson of the settlor and current Hereditary Trustee, challenged the Act before the Patna High Court. The High Court dismissed the writ petition, holding that the Trust was a “public trust” and that the Act was valid. The appellant then appealed to the Supreme Court.

(2) Issues Before the Court

1. Whether the 2015 Act is manifestly arbitrary and violative of Article 14 of the Constitution of India.
2. Whether the Act effects a compulsory acquisition of property in a confiscatory manner, thereby offending Article 300A read with Article 14.

(3) Key Legal Findings & Law Points

The Supreme Court allowed the appeal, striking down the Act as unconstitutional. The key legal principles established and applied in the judgment are as follows:

I. On Manifest Arbitrariness as a Ground to Strike Down Legislation (Article 14)

This is the central pillar of the judgment. The Court provides a detailed and authoritative restatement of the doctrine.

• Law Point 1: Arbitrariness is Antithetical to Equality.
  • The Court reaffirmed that Article 14 is not merely a prohibition against formal discrimination but a constitutional injunction against arbitrariness in all State action, whether executive or legislative. It traced this principle through a consistent line of authorities, starting with E.P. Royappa v. State of Tamil Nadu, which held that “equality is antithetic to arbitrariness.”
• Law Point 2: The Doctrine Applies to Plenary Legislation.
  • The Court explicitly overruled the effect of State of Andhra Pradesh v. McDowell & Co., which had suggested arbitrariness is not a ground to challenge plenary legislation.
  • Held: Relying on Shayara Bano v. Union of India, the Court affirmed that “manifest arbitrariness” is a valid and independent ground to strike down legislation under Article 14. The power must be exercised with restraint, but where “clear and substantive unreasonableness is embedded in a legislative enactment, the Court is not only empowered but obliged to intervene.”
• Law Point 3: Defining “Manifest Arbitrariness”.
  • Drawing from Shayara Bano, the Court defined manifest arbitrariness as something done by the legislature “capriciously, irrationally and/or without adequate determining principle. ” It also includes legislation that is “excessive and disproportionate” to its stated object.

Application of the Doctrine to the Present Case:

The Court found the 2015 Act to be manifestly arbitrary on multiple grounds:

• Disproportionate Means: The Act’s object was “better management.” However, the means adopted—complete vesting of property and dissolution of the trust—was the “most intrusive form of State intervention.” The Court held this was wholly disproportionate, especially given the absence of any finding of mismanagement against the Trustees.
• Lack of Rational Nexus & Adeguate Determining Principle: The record showed no legislative inquiry, no notice to the Trustees, and no evidence of mismanagement. The State Librarian, a government appointee, was responsible for day-to-day supervision, yet no action was ever taken against him. This demonstrated that the drastic action lacked any rational basis or guiding principle.
• Availability of Lesser Alternatives: The Court noted that the State’s objective could have been achieved through far less drastic measures like conditional grants-in-aid, statutory audits, and supervisory oversight. Choosing the most extreme measure when milder ones were available was itself a mark of arbitrariness.
• Selective Application: The Act singled out one institution, despite the State’s own record showing many other libraries were in a state of disrepair. This highlighted the absence of a “rational and principled approach.”

II. On the Right to Property and Compulsory Acquisition (Article 300A)

• Law Point 4: A Law Depriving Property Must Be Fair and Reasonable.
  • While Article 300A permits the State to deprive a person of their property by authority of law, such a law must still be “just, fair and reasonable, and not arbitrary or confiscatory in effect.”
  • Held: The compensation provision (Section 7), which capped compensation at a maximum of one rupee with no guiding principles, was “illusory” and “confiscatory.” It vested “unguided discretion” in the State and lacked the “basic attributes of fairness.” This reinforced the finding of manifest arbitrariness.

III. On the Characterisation of the Trust (Public vs. Private)

• Law Point 5: Courts Cannot Make out a New Case Not Pleaded.
  • The High Court had, on its own, concluded the trust was a “public trust” based on its public-facing object, even though both parties had argued on the assumption it was a private trust.
  • Relying on Bachhaj Nahar v. Nilima Mandal, the Supreme Court held this was impermissible. A court cannot make out a third case not pleaded by either party, as it denies the affected party the opportunity to rebut it.
• Law Point 6: Public Benefit Does Not Automatically Make a Trust “Public.”
  • The Court clarified that an institution serving a public purpose does not, by itself, make it a public trust in law. The legal character depends on factors like the dedication’s manner, the trust’s structure, control mechanisms, and the settlor’s reserved rights. In this case, the formal Deed of Trust, succession provisions, and reversionary clause were indicative of a private trust.

(4) Decision and Final Order

• The Supreme Court set aside the judgment of the Patna High Court.
• It declared the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015, as unconstitutional and struck it down for being manifestly arbitrary and violative of Article 14, and for failing to meet the standards of fairness required under Article 300A.
• The Trust, along with its rights of management and administration, was ordered to be restored to its pre-existing legal position.