VidhiSangh

Supreme Court of India · 10/03/2026

ANURAG KRISHNA SINHA versus STATE OF BIHAR & ANR.

[2026] 3 S.C.R. 465 · 2026 INSC 219

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Summary

The Court struck down the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 as manifestly arbitrary under Article 14. The Act vested a century-old trust institution in the State and dissolved the trust without any inquiry or finding of mismanagement, with less drastic means available, compensation capped at one rupee, and the same outcome as a lapsed 1983 ordinance. The High Court also erred in deciding the case on the unpleaded footing that the trust was public.

Issues

  1. Whether the High Court could decide the case on the basis that the trust was a public trust when neither party had pleaded or argued it.
  2. Whether the 2015 Act is manifestly arbitrary and violative of Article 14 of the Constitution.
  3. Whether the Act effects a compulsory, confiscatory acquisition offending Article 300A read with Article 14.

Provisions considered

Held

Result

Appeal allowed; High Court judgment dated 29.02.2024 set aside; the 2015 Act declared unconstitutional and struck down; the trust and its rights of management restored to their position before the Act, without precluding State financial assistance, administrative support or regulatory oversight in accordance with law.

Judgment PDF: Supreme Court of India, [2026] 3 S.C.R. 465.