Supreme Court Cancels Bihar Law to Take Over 100-Year-Old Library

The Supreme Court’s decision in Anurag Krishna Sinha v. State of Bihar represents an important reaffirmation of the constitutional doctrine that arbitrariness in legislation is incompatible with the guarantee of equality under Article 14.

The Court struck down the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015, holding that the statute, which sought to acquire and take over the management of a historic educational institution and library in Patna, was manifestly arbitrary and therefore unconstitutional.

What's The Matter?

The dispute arose out of the legislative takeover of the Smt. Radhika Sinha Institute and Sachchidanand Sinha Library, an institution founded in 1924 by Sachchidanand Sinha, who also served as the first temporary President of the Constituent Assembly of India.

The institution was established in memory of his wife, Smt. Radhika Sinha, through personal donations including property and an extensive collection of books.

The Trust Deed executed in 1926 structured the governance of the institution through trustees, while also providing a hereditary role for the eldest male member of the settlor’s family as Honorary Secretary and Chief Executive Officer.

Over decades, the library functioned as a major intellectual centre in Patna, receiving financial support from the Government of Bihar while retaining managerial control in the hands of the trustees.

The controversy emerged when the Bihar Legislature enacted the 2015 statute that effectively dissolved the trust and vested the entire institution and its assets in the State Government.

The law transferred all rights, title and interests in the Institute and Library to the State, required trustees to hand over property and records, and dissolved the trust structure that had governed the institution for nearly a century.

While the State justified the legislation on the ground of improving administration and development of the institution, the trustees challenged the enactment as unconstitutional.

At the heart of the case was the constitutional doctrine of arbitrariness under Article 14 of the Constitution of India. The Supreme Court traced the development of the doctrine through landmark precedents such as E.P. Royappa v. State of Tamil Nadu, Maneka Gandhi v. Union of India, and Ajay Hasia v. Khalid Mujib Sehravardi, which collectively established that equality and arbitrariness are constitutional opposites.

The Court also relied on the modern articulation of the doctrine of “manifest arbitrariness” in Shayara Bano v. Union of India, where it was clarified that legislation itself may be struck down if it is capricious, irrational or disproportionate.

Applying these principles, the Court found that the 2015 Act exhibited several features that rendered it constitutionally infirm.

The statute effected a complete transfer of ownership and management of the institution to the State without any prior inquiry or demonstrated failure of the trust’s functioning.

Importantly, the Court examined original government records and found no evidence that the State had ever accused the trustees of mismanagement, financial irregularity or neglect.

Nor had the government issued warnings, conducted investigations or attempted corrective regulatory measures before resorting to legislative acquisition.

In constitutional terms, the takeover therefore lacked any rational justification or proportional basis.

Another factor that weighed heavily with the Court was the role of the State itself in the management of the institution. Under the existing arrangement, the State Librarian served as the ex-officio Chief Librarian responsible for the general supervision of the institution’s functioning.

The Court noted that if mismanagement had indeed occurred, responsibility could not be attributed solely to the trustees when a government-appointed official was entrusted with supervisory authority.

The absence of any disciplinary action against the State Librarian further undermined the State’s justification for the takeover.

Equally significant was the compensation mechanism under the Act.

The statute permitted the State Government to award compensation up to a maximum of one rupee after examining claims.

The Court characterised this provision as effectively illusory and confiscatory. Although property rights are no longer fundamental rights, the Court reiterated that *Article 300A of the Constitution of India still requires that deprivation of property must occur through a fair, reasonable and non-confiscatory law.

A statutory framework allowing the State to acquire property while offering merely token compensation was therefore incompatible with constitutional fairness.

The Court also considered the legislative history surrounding the institution.

In 1983, the State had attempted to take over the trust through an ordinance.

That attempt ultimately failed when the ordinance lapsed and the Supreme Court restored the trust to its original position.

The Court observed that the 2015 Act sought to achieve substantially the same outcome decades later without any significant change in circumstances.

The absence of new evidence or justification reinforced the conclusion that the legislation was arbitrary.

Another striking aspect of the judgment was the Court’s critique of selective state action.

The State of Bihar itself had acknowledged that numerous public libraries across the state had deteriorated or ceased to function.

Yet the extreme measure of legislative takeover was applied only to this particular institution, which had remained operational. Such selective targeting without objective criteria further demonstrated the absence of a rational legislative policy.

On these cumulative grounds, the Supreme Court held that the statute was manifestly arbitrary and violative of Article 14.

The Act was therefore declared unconstitutional and struck down, and the trust governing the institution was restored to its original legal position.

At the same time, the Court clarified that the State was free to provide financial assistance, regulatory supervision or administrative support to the institution through lawful means.

The judgment is significant for at least two reasons.

First, it reinforces the doctrinal strength of the “manifest arbitrariness” test as a tool of judicial review against legislation.

Although courts traditionally exercise restraint in invalidating statutes, the decision underscores that legislative action cannot escape constitutional scrutiny when it operates without rational justification or proportionality.

Second, the case illustrates the continuing relevance of constitutional property protections even after the right to property was downgraded from a fundamental right. While Article 300A allows acquisition by law, the Court’s reasoning makes clear that such laws must still conform to standards of fairness and non-confiscation.

Ultimately, the decision reflects a deeper constitutional concern: the preservation of institutions built through private philanthropy for public intellectual life.

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Case Details:

ANURAG KRISHNA SINHA VS. STATE OF BIHAR - C.A. No. 13581/2025 - Diary Number 11052 / 2024 - 10-Mar-2026

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