Reviewed case brief

Pradeep Kumar Biswas and Ors. v Indian Institute of Chemical Biology and Ors.

(2002) 5 SCC 111

(2002) 5 SCC 111 · Supreme Court of India (Seven-Judge Bench)

article-12deep-and-pervasive-controlinstrumentality-of-statecsirseven-judge-bench
Court
Supreme Court of India (Seven-Judge Bench)
Year
2002
Subjects
Constitutional Law I
Reviewed
2026-08-02

Rule established

The determinative factor in deciding whether a body is 'State' under Article 12 is whether it is financially, functionally, and administratively dominated by, or under the deep and pervasive control of, the government; the Ajay Hasia factors are indicative pointers, not a rigid checklist.

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        (2002) 5 SCC 111; landmark seven-judge bench decision refining the Article 12 test

        Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.