Article 131 of Indian Constitution

The Indian Constitution is a dynamic document that provides a robust framework for governance, administration, and the protection of rights. Among its numerous provisions, Article 131 plays a critical role in defining the judicial authority of the Supreme Court (SC) concerning disputes between the Union and States or between multiple States. The exclusive and original jurisdiction granted to the SC under this article ensures that legal conflicts involving the distribution of powers between different levels of government are resolved effectively. This article will delve into the significance, scope, and limitations of Article 131, supported by relevant case laws and judicial interpretations.

What is Article 131 of Indian Constitution?

Article 131 of the Indian Constitution provides the original and exclusive jurisdiction to the Supreme Court in matters involving disputes:

1. Between the Government of India and one or more States.
2. Between the Government of India and one or more States on one side and one or more other States on the other side.
3. Between two or more States, provided the dispute involves a legal right.

The phrase “original jurisdiction” means that such cases can be directly filed in the Supreme Court without having to go through lower courts. Furthermore, “exclusive jurisdiction” implies that no other court, including High Courts, can adjudicate such disputes.

Nature and Scope of Article 131

The primary objective of Article 131 is to maintain the federal balance and ensure that legal disputes between the Centre and States, or among States themselves, are resolved efficiently. Some of its key characteristics include:

• Applicability to Legal Rights: The disputes must involve a question of law or fact regarding the existence or extent of a legal right. Purely political disputes are not covered under this provision.
• Does Not Include Private Individuals or Entities: Article 131 does not permit private citizens, companies, or even government departments to file cases under it, even if they are associated with a State Government in any dispute.
• Ensures Federal Stability: As India follows a quasi-federal structure, Article 131 provides a crucial mechanism for resolving intergovernmental disputes, ensuring cooperative federalism.

Landmark Cases on Article 131 of Indian Constitution

Several landmark judgements have helped define the scope and applicability of Article 131. Some of the significant cases are:

State of West Bengal v. Union of India (1963)

State of West Bengal v. Union of India was the first case where a State challenged the Union Government under Article 131. The dispute arose from the Acquisition and Development Act, 1947, which granted the Central Government the authority to acquire land and resources vested with State Governments. The State of West Bengal challenged Sections 4 and 7 of the Act, arguing that since India follows a federal structure, Parliament could not unilaterally acquire state-owned coal fields.

Key Issues

1. Did Parliament have the power to acquire land and properties vested in a State through legislation?
2. Were Indian States sovereign entities?

Supreme Court’s Ruling

• The Court rejected West Bengal’s claim of sovereignty, stating that India is not a purely federal state, and Parliament can acquire state property under its legislative authority.
• The suit was dismissed with costs, and no compensation was granted to West Bengal.
• The judgement clarified that while States have autonomy, they are subject to constitutional limitations imposed by the Union Government.

This case established that Article 131 does not give States absolute control over their resources if Parliament has legislative authority over the matter.

State of Karnataka v. Union of India (1977)

In State of Karnataka v. Union of India, Karnataka challenged Section 3 of the Commission of Inquiry Act, 1952, which empowered the Central Government to order a judicial inquiry against State Ministers, including the Chief Minister. Karnataka contended that Article 164(2) of the Constitution makes the State Cabinet responsible to the State Legislature, not to the Centre.

Supreme Court’s Observations

• The Court ruled that the distinction between State and State Government was irrelevant in this case.
• It upheld the validity of the Act, stating that federalism does not prevent the Centre from ensuring accountability within State administrations.

Maintainability of the Suit

• By a 4:3 majority, the Supreme Court ruled that the suit was maintainable under Article 131.
• Chief Justice M.H. Beg stated that if there is a constitutional interpretation issue, Article 131 can be invoked.
• Justice P.N. Bhagwati noted that a suit under Article 131 does not require an infringement of legal rights.

This ruling expanded the scope of Article 131, establishing that States can challenge Central legislation even if no direct legal right is infringed.

State of Madhya Pradesh v. Union of India (2011)

State of Madhya Pradesh v. Union of India case arose from Sections 58(3) and 58(4) of the MP Reorganisation Act, 2000, which gave the Centre authority over the distribution of assets and liabilities of State Electricity Boards. The Madhya Pradesh Government challenged the Act, arguing that it was violative of Article 14 (Right to Equality).

Supreme Court’s Ruling

• The Court dismissed the suit, holding that Article 131 cannot be invoked for challenging fundamental rights violations.
• It ruled that laws violating fundamental rights should be challenged under Article 32 (Supreme Court) or Article 226 (High Courts).

This was the first case where the Supreme Court explicitly rejected a suit under Article 131 for fundamental rights violations. It set a precedent that States cannot use Article 131 for issues concerning individual rights.

State of Jharkhand v. Union of India (2012)

Jharkhand challenged the Bihar Reorganisation Act, 2000, specifically the provisions related to pension liabilities of former Bihar employees. The Union Government argued that the Madhya Pradesh v. Union of India judgement applied and that the suit was not maintainable.

Supreme Court’s Observations

• Unlike the Madhya Pradesh case, the Court did not agree that the suit was non-maintainable.
• It referred the case to a larger bench, emphasising that if a constitutional question arises, the Supreme Court has the authority to examine it.

State of Jharkhand v. Union of India ruling created conflicting opinions on the scope of Article 131, as it contradicted the 2011 Madhya Pradesh case.

State of Kerala v. Union of India (2020)

State of Kerala v. Union of India case arose from the controversial Citizenship Amendment Act (CAA), 2019, which granted fast-track citizenship to non-Muslim minorities from Pakistan, Afghanistan, and Bangladesh. The State of Kerala challenged the CAA, arguing that it violated Articles 14, 21, and 25 of the Constitution.

Key Arguments by Kerala

• The Act discriminates based on religion, violating Article 14 (Right to Equality).
• It affects religious freedom under Article 25.
• The Passport (Amendment) Rules, 2015, and Foreigners (Amendment) Order, 2015, which regulate citizenship, were also challenged.

Legal Significance

• The maintainability of the suit was not challenged, suggesting that the Centre recognised the validity of Kerala’s concerns under Article 131.
• Kerala also questioned why Muslim minorities from other neighboring countries (e.g., Sri Lanka, Myanmar) were excluded from CAA’s benefits.

This case is crucial as it extends the use of Article 131 to challenge laws that impact constitutional rights and federalism. A larger bench is expected to determine its final status.

State of Chhattisgarh v. Union of India (2020)

Chhattisgarh filed a suit against the National Investigation Agency (NIA) Amendment Act, 2019, arguing that it violates federalism by giving the Centre control over State police functions.

• The State argued that the Act allows Central agencies to operate within State boundaries without State consent, undermining State autonomy.
• Similar to Kerala’s suit, the maintainability under Article 131 is likely to be decided by a larger bench.

Restrictions on Article 131 of Indian Constitution

While Article 131 grants substantial authority to the SC, certain restrictions limit its application:

1. Exclusion of Treaty-Related Disputes: If a dispute arises from a treaty, agreement, covenant, or engagement executed before the Constitution’s commencement, Article 131 does not apply.
2. Inter-State River Water Disputes: The Parliament has the power to exclude the jurisdiction of the SC in matters relating to the use, distribution, or control of inter-state river waters. Such disputes are generally resolved through Inter-State River Water Disputes Tribunals under Article 262.
3. Suits Brought by Private Individuals: Article 131 does not allow private individuals or companies to file cases directly in the Supreme Court. Even if a private entity is affected along with a State Government, the dispute does not qualify under Article 131.

Significance of Article 131 in Indian Federalism

Article 131 acts as a safeguard against constitutional violations and promotes harmony between the Centre and States. Its importance lies in:

1. Preventing Federal Conflicts: It provides a peaceful resolution mechanism for legal disputes between different levels of government.
2. Ensuring Constitutional Supremacy: Any conflict regarding legal interpretation is resolved by the highest judicial authority, ensuring compliance with constitutional principles.
3. Strengthening Cooperative Federalism: While disagreements between the Centre and States are natural, Article 131 ensures they are resolved legally rather than politically.

Conclusion

Article 131 of the Indian Constitution is a crucial provision that upholds the federal structure of India by granting exclusive jurisdiction to the Supreme Court in legal disputes involving the Union and States. However, its applicability is limited to legal rights and does not cover political conflicts. Judicial precedents have further clarified that policy decisions, financial allocations, and administrative matters do not fall under its scope.

As federal relations continue to evolve, Article 131 remains a critical tool for maintaining constitutional harmony and dispute resolution in India’s governance framework. The Supreme Court’s interpretations and rulings on this provision will continue to shape its relevance in the years to come.