Complete Vesting Of Trust Property In State Without Safeguards Manifestly Arbitrary: Supreme Court Strikes Down Bihar Law On Century-Old Sinha Library
Court strikes down Bihar’s 2015 Act, holding deprivation of property without fair compensation and due process violates Articles 14 and 300A
Justice Vikram Nath, Justice Sandeep Mehta, Supreme Court
The Supreme Court has struck down the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015, declaring it unconstitutional and restoring the management of the historic institution to its original trust.
The Court held that the Act empowered the State to take over the institute and library entirely by dissolving existing legal arrangements and divesting long-standing rights without any demonstrated necessity, objective criteria, or prior inquiry. It observed that such sweeping power, exercised in the name of “better management and development”, was excessive, unreasoned, and disproportionate, rendering the Act manifestly arbitrary and violative of Article 14 of the Constitution of India.
The Court further noted that the Act allowed deprivation of property without adhering to basic principles of fairness and due process, particularly because it lacked any clear or meaningful framework for compensation. While Article 300A of the Constitution of India permits deprivation of property by authority of law, the Court emphasized that such law must be fair, reasonable, and non-confiscatory, a standard the impugned legislation failed to satisfy.
Justice Vikram Nath and Justice Sandeep Mehta while setting aside the Patna High Court’s judgment dated 29-02-2024 observed, “Viewed cumulatively, the scheme of the impugned Act reveals a pattern of arbitrariness: complete vesting of property in the State, dissolution of long-standing trust arrangements, absence of any finding of necessity or mismanagement, provision for illusory compensation, and lack of guiding principles or safeguards. Each of these features, taken individually, raise serious constitutional concern; taken together, they render the enactment manifestly arbitrary in its conception and operation”.
“It is also material that the impugned Act targets a single institution for complete takeover, without disclosing any intelligible basis for such exclusive treatment. The State’s own material indicates that several public libraries in the State have ceased to function or are in a state of disrepair. The selective application of an extreme legislative measure to a functioning institution, without objective criteria, further underscores the absence of a rational and principled approach”, the Bench further categorically observed.
The Court declared the 2015 Act unconstitutional and ordered that the trust governing the Institute and Library be restored to its pre-existing legal position, along with its rights of management and administration.
However, the bench clarified that the State Government may continue to provide financial assistance, administrative support, or regulatory oversight in accordance with law, without assuming control of the institution.
Senior Advocate Sunil Kumar appeared for the appellant and Advocate Divyansh Mishra appeared or the respondent.
In the matter, the dispute concerned a historic educational and library institution established in 1924 by Sachchidanand Sinha, a prominent public figure and the first President (Provisional) of India’s Constituent Assembly. The Bihar legislation had allowed the state to requisition and manage the institution, which was challenged as unconstitutional by the appellant.
The Patna High Court had upheld the 2015 Act, observing that the legislation was enacted to ensure better management, preservation, and development of the historic public library and institute. The High Court accepted the State’s contention that the institution had fallen into administrative and functional difficulties and that temporary takeover and management by the government was a legitimate legislative measure in public interest, particularly to safeguard a culturally and historically significant public institution.
The Supreme Court, thus, allowing the appeal, held that the High Court’s judgment upholding the Act could not be sustained, and accordingly struck down the law while restoring the autonomy of the trust managing the institute and library.
Cause Title: Anurag Krishna Sinha v. State Of Bihar & Anr. [Neutral Citation: 2026 INSC 219]
Appearances:
Appellant: Sunil Kumar, Sr. Adv., Rohini Prasad, AOR, Ashika Ranjan, Advocates.
Respondent: Manish Kumar, AOR, Divyansh Mishra, Kumar Saurav, Mrigank Prabhakar, AOR, Astha Singh, N.R. Shwetabh, Advocates.