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Which of the following is NOT a 'state' within the meaning of state under Article 12 of the Constitution of India?

Question and options

Which of the following is NOT a 'state' within the meaning of state under Article 12 of the Constitution of India?
  1. BCCI
  2. State Bank of India
  3. Airport Authority of India
  4. Rajasthan Electricity Board

Answer and explanation

Correct answer: A - BCCI
In Zee Telefilms Ltd v Union of India (2005), a Constitution Bench held by majority that the Board of Control for Cricket in India is not 'State' under Article 12, because it is not financially, functionally or administratively controlled by the Government, though it may answer to writ jurisdiction under Article 226 because it performs public functions. The State Bank of India, the Airports Authority of India and a State Electricity Board are statutory bodies under deep governmental control, and so are 'State'.

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