Allahabad HC: Gandhi Ashram Not A ‘State’ Under Article 12

In a significant judicial pronouncement, the Allahabad High Court has clarified that the Regional Shri Gandhi Ashram in Meerut does not fall under the ambit of ‘State’ as defined in Article 12 of the Constitution of India.

Justice J J Munir delivered the ruling in response to a petition filed by Prem Chandra, a former supervisor at the Ashram.

The court ruled that the Ashram, operating as a registered private society, does not meet the criteria under Article 12 to be classified as a ‘State’.

This determination had direct implications on the maintainability of Chandra’s petition filed under Article 226, challenging his dismissal and eviction from residential quarters.

Justice Munir, citing legal precedents such as Suresh Ram vs State of Uttar Pradesh and Ram Bachan Singh vs Chief Executive Officer Khadi Village Industries and others, underscored that entities similar to the Ashram do not qualify as ‘State’ under the constitutional framework.

This reaffirmation formed the basis of the court’s decision to dismiss Chandra’s petition, as it lacked statutory grounds to intervene in the Ashram’s internal affairs.

Chandra, during the proceedings, had raised allegations of financial improprieties and procedural irregularities within the Ashram.

The court acknowledged these grievances but maintained that without specific legislative authority regulating the Ashram’s operations, Article 226 did not warrant judicial intervention.

The defense argued convincingly that the Ashram, governed primarily by the Societies Registration Act, 1860, and the Uttar Pradesh Khadi and Village Industries Board Act, 1960, does not perform functions that would classify it as an entity under state control.

This argument was pivotal in the court’s determination that the Ashram falls outside the scope of ‘State’ for constitutional purposes.

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