बी.एस. मिन्हास बनाम भारतीय सांख्यिकी संस्थान
| Citation | (1984) 1 SCC 131 |
| Court | Supreme Court of India |
| Date | 28 September 1983 |
| Year | 1984 |
| Bench | Y.V. Chandrachud CJ, D.P. Madon, O. Chinnappa Reddy JJ. |
| Acts/Articles | Article 12, Article 14, Article 16 |
| Category | Constitutional Law, Service & Employment Law |
Key Principle Established
An institution receiving government grants is "State" under Article 12. Employees of such bodies are entitled to Article 14 and 16 protection against arbitrary termination.
An employee of the Indian Statistical Institute was terminated. He challenged the termination arguing that the Institute, being substantially funded by the government, was “State” under Article 12 and must follow principles of natural justice.
The Court held that an institution receiving substantial government funding and under deep and pervasive government control is “State” within the meaning of Article 12. Such bodies must follow Articles 14 and 16, and their employees are entitled to protection against arbitrary dismissal.
This judgment expanded the definition of “State” for employment purposes, bringing government-aided institutions, corporations, and societies under constitutional obligations. It is relied upon in disputes involving employees of autonomous bodies, registered societies, and public sector undertakings.
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Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.