ANURAG KRISHNA SINHA versus STATE OF BIHAR & ANR.

ANURAG KRISHNA SINHA versus STATE OF BIHAR & ANR.

The Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is manifestly arbitrary and violative of Article 14 because it effects a complete vesting and dissolution of long-standing trust arrangements without demonstrated necessity, objective criteria, inquiry or proportionate means; further, its scheme permits deprivation of property without fair and non-confiscatory compensation in breach of Article 300A, and therefore the Act is unconstitutional and must be struck down with restoration of the trust to its pre-enactment legal position.

Parties
Appellant: Anurag Krishna Sinha; Respondent: State of Bihar
Jurisdiction
India
Judgment Date
10 March 2026
Procedural Posture
Civil Appeal (civil Appeal No. 13581 of 2025) / Appeal From the Judgment and Order Dated 29.02.2024 of the High Court of Judicature at Patna in CWJC No. 7940 of 2015; Supreme Court Judgment Allowing Appeal
Outcome
Appeal allowed; impugned Act declared unconstitutional and struck down
Legal Topics
Article 14, Article 300 a, Compulsory Acquisition, Public Trust, Manifest Arbitrariness, Compensation, Legislative Competence, Repugnancy
Constitutional Law Property Law Trusts and Trustees Law Administrative Law Article 14 Article 300 a Compulsory Acquisition Public Trust +4 more

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Parties

Anurag Krishna Sinha

Appellant

State of Bihar

Respondent

Procedural Posture

Civil Appeal (civil Appeal No. 13581 of 2025) / Appeal From the Judgment and Order Dated 29.02.2024 of the High Court of Judicature at Patna in CWJC No. 7940 of 2015; Supreme Court Judgment Allowing Appeal

Legal Issues

  1. 1 Whether the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is manifestly arbitrary and violative of Article 14 of the Constitution of India
  2. 2 Whether the impugned Act effects compulsory acquisition and extinguishment of rights in a confiscatory manner, thereby offending Article 300A read with Article 14 of the Constitution of India

Ratio Decidendi

The Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is manifestly arbitrary and violative of Article 14 because it effects a complete vesting and dissolution of long-standing trust arrangements without demonstrated necessity, objective criteria, inquiry or proportionate means; further, its scheme permits deprivation of property without fair and non-confiscatory compensation in breach of Article 300A, and therefore the Act is unconstitutional and must be struck down with restoration of the trust to its pre-enactment legal position.

Court Disposition

Appeal allowed; impugned Act declared unconstitutional and struck down

Orders

  • The judgment and order dated 29.02.2024 of the High Court of Judicature at Patna in CWJC No. 7940 of 2015 is set aside
  • The Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is declared unconstitutional and struck down