Writs Against Private Bodies Under Article 226: A Comprehensive Legal Analysis

Introduction

The question of whether writ jurisdiction under Article 226 of the Constitution of India extends to private bodies has been a subject of extensive judicial deliberation. While Article 226 prima facie applies to actions by the State and its instrumentalities, the Supreme Court has evolved a nuanced jurisprudence that permits writ remedies against private entities in specific circumstances.

Constitutional Framework

Article 226 of the Indian Constitution empowers High Courts to issue writs for enforcement of fundamental rights under Part III and “for any other purpose.” The jurisdiction is broader than Article 32, which is limited to fundamental rights enforcement. The key question has always been: what constitutes “appropriate proceedings” against private bodies?

Evolution of Judicial Societies: Early Restrictive Approach

Initially, courts adopted a restrictive interpretation, limiting writ jurisdiction primarily to State actions.

Leading Cases on Writ Jurisdiction Against Non-State Bodies

The leading cases in this regard is as under:

1. University of Delhi v. Ram Nath, AIR 1963 SC 1873

The Supreme Court held that writs under Article 226 are ordinarily available against the State or statutory authorities performing public duties. The Court emphasized:

“A writ of certiorari could be issued only if the body or the tribunal against which it was issued was exercising, when it made the order complained of, power to adjudicate or determine questions of a judicial or quasi-judicial character. But the scope of the writ of certiorari has been enlarged by judicial decisions, and today it is settled that certiorari can be issued not only to quash a judicial or quasi-judicial order but also against decisions of administrative authorities… Writs in the nature of prerogative writs can be issued under Article 226 to any person or authority, including in appropriate cases, any Government, for the enforcement of any of the rights conferred by Part III and for any other purpose.”

The Court clarified that private individuals or bodies not discharging any public duty are generally outside the purview of writ jurisdiction.

2. The Watershed: Pradeep Kumar Biswas v. Indian Institute of Chemical Biology, (2002) 5 SCC 111

This landmark judgment marked a paradigm shift. The Supreme Court held that a writ of certiorari can lie against a private body if it is entrusted with public duty. Justice S.N. Variava, writing for the Court, observed:

“The distinction between a ‘private’ body and a ‘public’ body may be illusory. The dividing line between ‘private’ and ‘public’ is becoming thinner. Given this, we are of the opinion that a writ of certiorari would be maintainable even if the body is not a statutory body and is not even an instrumentality or agency of the Government. If the body is performing public functions then it becomes amenable to writ jurisdiction. The concept of public function has thus now become an important and determinative criterion in examining whether the writ petition would be maintainable… What matters is not the nature of the body but the nature of the duty.”

The Court laid down several crucial principles:

• The test is whether the body performs public duty
• The nature of the duty, not the status of the body, is determinative
• If significant public interest is involved, writ jurisdiction may be invoked
• The functional approach trumps formalistic classifications

Tests for Determining Amenability to Writ Jurisdiction

3. The Public Function Test: Binny Ltd. v. V. Sadasivan, (2005) 6 SCC 657

The Supreme Court elaborated on the “public function” test, holding that when a private body performs functions of a public nature affecting citizens’ rights, it becomes amenable to writ jurisdiction. Justice S.B. Sinha, writing for the Court, observed:

“The right to enforce the public duty by the instrumentality of writs or orders is a discretionary power, meaning thereby that when the Court finds that the performance of a public duty could be properly enforced by other equally efficacious legal remedies, it would not ordinarily issue a writ. The basic purpose of statutory provisions for issuance of directions, orders or writs in the nature thereof is to keep various authorities within the limits of their jurisdiction… The term ‘authority’ used in Article 226 is very wide and comprehensive and includes within its ambit all authorities created by statute on whom powers are conferred by law. Although, authorities are generally State authorities, they need not necessarily and always be State authorities. Private bodies can also be authorities if the following requirements are fulfilled:

• (i) If the body performs public function and is discharging public duty; and
• (ii) The body is financed by the State, State-aided, or enjoying statutory monopoly.

The Court stated that the touchstone is whether the function being performed is governmental or public in nature.

4. Anadi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsav Smarak Trust v. V.R. Rudani, (1989) 2 SCC 691

The Court held that a writ petition is maintainable against a private trust managing a temple if the affairs of the temple are of a public character and public interest is involved. Justice Natarajan, writing for the Bench, observed:

“A temple or other place of religious worship is also a juristic person and its interests have to be looked after and protected by someone who will act as its manager or trustee… The head of a mutt though designated as the Mahant and treated as an institution by himself will be essentially a trustee and his office, legal personality and duties would be limited and would not go beyond the purposes for which the mutt or the religious institution came into existence… In cases where the management of a religious institution is vested in a body of persons or committees, the trust character of the institution is predominant. The temples or religious institutions owned by such trusts would not be subjected to the personal enjoyment or disposition of any individual or individuals and as such they cannot by any stretch of imagination be treated as ‘private temples’ or ‘private institutions’.”

The Court observed that wherever there is a public element coupled with governmental control or funding, writ jurisdiction can be invoked.

5. The Deep and Pervasive State Control Test: Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649

The Supreme Court held that even a private body may be subject to writ jurisdiction if it is under deep and pervasive State control. The degree of State control, financial assistance, and the nature of functions performed are relevant factors.

6. Ajay Hasia v. Khalid Mujib Sehravardi, (1981) 1 SCC 722

This case established the famous “instrumentality of State” test. A body becomes an instrumentality of the State if:

• It is created by statute or under statutory powers
• The entire share capital is held by the government
• It enjoys monopoly status conferred by the State
• Functions of deep and pervasive public importance are transferred to it
• The government has deep and pervasive control over its management

7. The Monopoly Test: Board of Control for Cricket in India (BCCI) v. Cricket Association of Bihar, (2015) 3 SCC 251

In this significant judgment, the Supreme Court held that BCCI, despite being a private body, performs public functions and exercises monopolistic control over cricket in India. The Court held that such bodies are amenable to writ jurisdiction under Article 226. Justice R.M. Lodha, heading the three-judge Bench, comprehensively analyzed the nature of BCCI’s functions:

“We have perused the Memorandum of Association and Rules and Regulations of the BCCI and it is clear that it is a society registered under the Tamil Nadu Societies Registration Act. However, though the BCCI is ostensibly a private body, in discharge of its functions, it performs public functions. The BCCI selects the national team for the purpose of participating in the international matches, which involves selection of players from the State Associations… The BCCI also exercises a monopoly over cricket in India. The BCCI is the only body regulating and controlling cricket and it also represents India in the International Cricket Council (ICC). It performs a public function and duty, as it selects players to represent India in international cricket matches… There is no doubt that cricket has become the most important sport in India and the performance of the Indian cricket team generates tremendous public interest… Therefore, it is necessary for the BCCI to discharge its public duty in a fair, proper, transparent and non-discriminatory manner.”

The Court emphasized:

“Thus, even though the BCCI is not a State within the meaning of Article 12 of the Constitution, it is subject to the duties and obligations of public law and is amenable to writs under Article 226 of the Constitution. The BCCI performs ‘public function’ and enjoys monopoly in organising cricket in India. Therefore, the principle of accountability and good governance must apply to it.”

This case was monumental in establishing that monopolistic control over an important aspect of public life brings private entities within constitutional scrutiny.

Specific Categories of Private Bodies

Educational Institutions

1. J.P. Unnikrishnan v. State of Andhra Pradesh, (1993) 1 SCC 645 The Supreme Court held that even private unaided educational institutions are subject to reasonable regulations and can be amenable to writ jurisdiction when they violate constitutional rights or statutory provisions. Justice Jeevan Reddy, writing for the Constitution Bench, observed: “The right of private educational institutions to administer their institutions, is subject to the regulatory power of the State. This power has to be inferred from the very nature of the right created by Article 30, the purpose for which it is provided, and by its relationship to other provisions of the Constitution… Every statute regulating grant of affiliation to educational institutions, which lays down the conditions subject to which alone an educational institution can be affiliated to a university or a board, including conditions prescribing qualifications of teachers, the courses of studies, etc., is one which regulates the manner of exercise of the right to establish and administer educational institutions.”
2. T.M.A. Pai Foundation v. State of Karnataka, (2002) 8 SCC 481 The Court recognized the right of private institutions to establish and administer educational institutions but held that they are subject to writ jurisdiction for ensuring compliance with admission procedures, fee structures, and standards of education. Chief Justice Kirpal, writing for the eleven-judge Bench, held: “Regulation of education, be it medical or otherwise, including the standard of education, is a necessary concomitant to the power of establishing and maintaining educational institutions… The right of the private educational institutions to establish and administer their institutions, in the interests of ensuring excellence of education, would be subject to reasonable regulations, and the regulatory measures can relate to the competence of teachers, teaching staff, curriculum, infrastructure and the method of selection and admission of students. These are the areas which can be regulated. Regulations which go beyond this and control every aspect of management, such as the strength of staff, the salaries payable to them, the fixation of tuition and other fees and interference with the day-to-day management of the institutions, are not valid.”
3. Islamic Academy of Education v. State of Karnataka, (2003) 6 SCC 697 Following T.M.A. Pai Foundation, the Court reiterated that private educational institutions performing public functions are amenable to writ jurisdiction, particularly concerning admission procedures and fee regulations.

Cooperative Societies

1. Bihar State Cooperative Bank Ltd. v. Shree Hari Chandra Prasad Singh, (2009) 16 SCC 559 The Supreme Court held that cooperative societies performing public functions and having State patronage are amenable to writ jurisdiction under Article 226.
2. Zoroastrian Co-operative Housing Society Ltd. v. District Registrar Co-operative Societies (Urban), (2005) 5 SCC 632 The Court held that writs can lie against housing cooperative societies when issues of discrimination and violation of constitutional rights arise, particularly under Articles 14, 15, and 19.

Sports Bodies

1. Indian Olympic Association v. Veeresh Malik, (2011) 4 SCC 778 The Court held that sports bodies like the Indian Olympic Association, though registered as societies, perform public functions and are amenable to writ jurisdiction.
2. BCCI v. Cricket Association of Bihar (Supra) Building on earlier precedents, the Court comprehensively analyzed how sports bodies exercising monopolistic control and performing public functions fall within the ambit of Article 226.

Statutory Corporations

1. Electricity Board, Rajasthan v. Mohan Lal, (1967) 3 SCR 377 The Supreme Court held that statutory corporations created for public purposes are “State” under Article 12 and therefore amenable to writ jurisdiction.
2. R.D. Shetty v. International Airport Authority, (1979) 3 SCC 489 The Court held that authorities created by statute for public purposes and substantially controlled by the government are “State” under Article 12 and subject to writ jurisdiction.

Companies Substantially Controlled by Government

Key Supreme Court Precedents On Government Companies

1. Som Prakash Rekhi v. Union of India, (1981) 1 SCC 449 The Supreme Court held that government companies substantially controlled by the State are amenable to writ jurisdiction as they constitute “State” under Article 12.
2. Central Inland Water Transport Corporation v. Brojo Nath Ganguly, (1986) 3 SCC 156 The Court held that a government company is an authority under Article 12 and is bound by Articles 14 and 16 of the Constitution, making it subject to writ jurisdiction. Justice A.P. Sen, writing for the Constitution Bench, observed: “The Central Inland Water Transport Corporation Ltd. is a company owned by the Central Government… The question is whether the Corporation is a ‘State’ within the meaning of Article 12. In our opinion, it is. It is a Government company as defined in Section 617 of the Companies Act, 1956, in which not less than 51% of the paid up capital is held by the Central Government, and the Central Government has control over its management. It has, therefore, to be regarded as an instrumentality or agency of the Government… The Government companies, if they are instrumentalities or agencies of the Government, may, therefore, be subjected to the same constitutional or public law limitations as the Government.” It further observed thus: “Where the Government is the owner of the company, the activities of the Government company partake of the character of State activity and the Government company would be subject to the same constitutional limitations as the Government.”

Limitations And Exceptions

Pure Private Actions

1. Sukhdev Singh v. Bhagatram Sardar Singh Raghuvanshi, (1975) 1 SCC 421 While expanding the definition of “State,” the Court maintained that purely private bodies without any public function or State connection remain outside writ jurisdiction.
2. Naresh Shridhar Mirajkar v. State of Maharashtra, AIR 1967 SC 1 The Court emphasized that judicial review under Article 226 is not available against purely private actions that do not involve any public element.

Alternative Remedies

1. Whirlpool Corporation v. Registrar of Trade Marks, (1998) 8 SCC 1 The Court held that even when writ jurisdiction technically exists, if adequate alternative remedies are available, courts may decline to exercise extraordinary jurisdiction under Article 226.
2. State Bank of Patiala v. S.K. Sharma, (1996) 3 SCC 364 The Court reiterated that the existence of alternative statutory remedies is a factor in determining whether to exercise writ jurisdiction, though it is not an absolute bar.
3. The Authorised Officer, South Indian Bank Ltd. v. Sheela Francis Parakkal, W.A. No. 1498 of 2025 (Kerala High Court, decided: December 15, 2025) This very recent judgment from the Kerala High Court provides the latest clarification on the non-amenability of private commercial banks to writ jurisdiction, reinforcing longstanding precedent. Facts Sheela Francis Parakkal filed a writ petition seeking return of original title deeds from South Indian Bank Ltd., a private scheduled bank, nine years after closure of the joint loan account. The Single Judge passed a declaration that the bank had no authority to retain the deeds but declined to provide directions for their release citing non-availability. The Court also imposed costs of ₹50,000 on the bank. South Indian Bank appealed the decision. Key Holdings By Division Bench (Justice Arvind Sushrut Dharmadhikari and Justice Syam Kumar V.M.) The Division Bench unequivocally held: “Admittedly, in the present case, the appellant bank is a private commercial bank, therefore, the same is not amenable to writ jurisdiction under Article 226 of the Constitution of India. The learned Single Judge has committed an error in entertaining the Writ Petition and issuing certain directions.”

Reliance on Precedent

The Court relied heavily on two key precedents:

Case	Citation	Principle Laid Down
Federal Bank Ltd. v. Sagar Thomas	(2003) 10 SCC 733	Where the Supreme Court held that private banks are not amenable to writ jurisdiction.
Mathew Ignitious C. v. Catholic Syrian Bank Limited	(2019) 5 KHC 835	Where the Kerala High Court specifically held: “The private scheduled bank registered under the Companies Act do not fall within the purview of ‘State’ or other authorities under Article 12 of the Constitution of India.”

Court’s Reasoning

The Division Bench emphasized:

“As such, the judgment of the learned Single Judge is hereby set aside. The Writ Petition stands dismissed as not maintainable.”

The Court further clarified that the petitioners (loan account holders and legal heirs) were at liberty to work out their remedies in accordance with law before appropriate forums—meaning they should pursue civil remedies rather than constitutional remedies.

Arguments Rejected

The petitioners had argued that:

• Private banks discharge public functions
• Non-return of documents after 9 years amounted to violation of fundamental rights
• Banking services being essential made banks amenable to writ jurisdiction

However, the Court rejected these arguments, holding that merely performing banking operations or being subject to RBI regulations does not transform a private bank into a public authority for purposes of Article 226.

Significance of This Judgment

This recent judgment represents the current position of law in Kerala and reinforces that private commercial banks, despite their regulated status and importance to the economy, remain outside the purview of writ jurisdiction.

The case emphasizes that functional regulation by statutory bodies (like RBI oversight) does not automatically convert private entities into “State” under Article 12.

S. Shobha v. Muthoot Finance Ltd., 2025 INSC 117

Decided: January 24, 2025

This recent Supreme Court judgment provides crucial clarification on the limits of writ jurisdiction against private financial entities and reaffirms the primacy of the “function test.”

Facts

The petitioner, S. Shobha, availed a gold loan from Muthoot Finance Ltd., a Non-Banking Financial Company (NBFC). Upon defaulting on repayment, Muthoot Finance auctioned the pledged gold as per the loan agreement. The petitioner challenged the auction through a writ petition, alleging violation of an interim court order.

Key Holdings

The Supreme Court, through a Division Bench comprising Justice J.B. Pardiwala and Justice R. Mahadevan, held:

“While the Court examined the appeals and considered the controversy raised in the petitions, a conspicuous aspect surfaced that the petitions were filed against the Company named Muthoot Finance Limited. Admittedly, the respondent – Company is a Company registered under the Companies Act, 1956. It does not answer the definition of ‘State’ within meaning of Article 12 of the Constitution. Nor the transaction of loan by pledging gold between the petitioner and the respondent could be said to be involving any public function or could be said to be in the public realm. Also the Company is not discharging any function which has the trapping of sovereign function. Respondent – Company is a Private Company registered under the law. It is not a ‘State’. Once the above position is clear, the writ petitions would not lie against the respondent – Company.”

Critical Observations

Regulatory Oversight Does Not Equal Public Function: The Court clarified that mere compliance with RBI regulations does not convert a private NBFC into a public authority:

“Although a non-banking finance company like the Muthoot Finance Ltd. with which we are concerned is duty bound to follow and abide by the guidelines provided by the Reserve Bank of India for smooth conduct of its affairs in carrying on its business, yet those are of regulatory measures to keep a check and provide guideline and not a participatory dominance or control over the affairs of the company.”

Banking Business as Private Function

The Court emphasized:

“A private company carrying on banking business as a Scheduled bank cannot be termed as a company carrying on any public function or public duty.”

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Public Duty Requirement for Writs

The Court reiterated:

“Normally, mandamus is issued to a public body or authority to compel it to perform some public duty cast upon it by some statute or statutory rule. In exceptional cases a writ of mandamus or a writ in the nature of mandamus may issue to a private body, but only where a public duty is cast upon such private body by a statute or statutory rule and only to compel such body to perform its public duty.”

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The Function Test Prevails

The Court emphasized:

“If a private body is discharging a public function and the denial of any rights is in connection with the public duty imposed on such body, the public law remedy can be enforced. The duty cast on the public body may be either statutory or otherwise and the source of such power is immaterial but, nevertheless, there must be the public law element in such action.”

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Significance

• This judgment reinforces that private financial entities, even when heavily regulated, do not automatically become amenable to writ jurisdiction.
• The presence of regulatory oversight by statutory bodies like RBI is insufficient to invoke constitutional remedies.
• Aggrieved parties must pursue civil remedies, arbitration, or contractual dispute resolution mechanisms.

The case provides clear guidance that the “function test” remains paramount, and courts must examine whether the entity performs functions of a genuinely public nature rather than merely complying with regulatory requirements applicable to private commercial activities.

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Earlier Recent Developments

Public Trust Doctrine

Case	Key Principle
M.C. Mehta v. Kamal Nath, (1997) 1 SCC 388	The Supreme Court invoked the public trust doctrine, holding that when natural resources or public assets are involved, even private entities managing such resources can be subject to writ jurisdiction.
M.I. Builders Pvt. Ltd. v. Radhey Shyam Sahu, (1999) 6 SCC 464	The Court held that when private builders undertake construction affecting public interest or utilizing public resources, writ jurisdiction may be invoked to ensure compliance with building regulations and environmental norms.

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Digital Age Considerations

Case	Key Observation
Shreya Singhal v. Union of India, (2015) 5 SCC 1	While dealing with intermediary liability, the Court recognized that private digital platforms performing quasi-public functions may be subject to constitutional scrutiny, opening avenues for future extension of writ jurisdiction.
Anuradha Bhasin v. Union of India, (2020) 3 SCC 637	The Court held that restrictions on internet access, even through private telecom operators acting on government directions, are subject to constitutional scrutiny under Article 19.

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Legal Arguments in Favor of Writ Jurisdiction

• Functional Approach: The emphasis should be on the nature of the function rather than the formal status of the body. If public functions are being performed, accountability mechanisms must exist.
• Constitutional Accountability: Private bodies wielding significant power over citizens’ lives should be subject to constitutional discipline, ensuring adherence to principles of fairness, reasonableness, and non-arbitrariness.
• Access to Justice: Denial of writ jurisdiction against powerful private entities may leave citizens without effective remedies, particularly when alternative remedies are inadequate or non-existent.
• Evolution of State Functions: The modern State increasingly delegates functions to private bodies through privatization, outsourcing, and public-private partnerships. Constitutional accountability must follow such delegation.
• Public Interest Protection: When private bodies affect substantial public interests, judicial oversight is necessary to prevent abuse of power and protect vulnerable sections of society.

Legal Arguments Against Extension of Writ Jurisdiction

Textual Interpretation

Article 226 traditionally applies to the State, and its extension to private bodies may exceed constitutional limits.

Alternative Remedies

Civil remedies through ordinary courts may be more appropriate for disputes with private entities.

Contractual Autonomy

Excessive expansion may undermine private autonomy and freedom of contract, essential for economic liberty.

Judicial Overreach

Courts should not substitute their judgment for business decisions of private entities absent clear constitutional violations.

Burden on Judiciary

Extending writ jurisdiction indiscriminately may overwhelm High Courts with matters better suited for civil adjudication.

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Synthesis: The Current Legal Position

The current legal position can be summarized as follows:

Writs Lie Against Private Bodies When

• Public Duty Performance: The private body performs functions of a public nature affecting citizens at large (Pradeep Kumar Biswas)
• State Instrumentality: The body is substantially controlled by the State or functions as its instrumentality (Ajay Hasia)
• Monopolistic Control: The body exercises monopolistic control over essential services or activities (BCCI case)
• Statutory Rights Violation: The body violates statutory rights or duties, coupled with public interest (Binny Ltd.)
• Fundamental Rights Infringement: The body’s actions result in violation of fundamental rights with State complicity or enabling
• Public Resources Management: The body manages public resources or assets held in public trust (M.C. Mehta)

Writs Generally Do Not Lie When

• The body is purely private with no public function
• Adequate alternative remedies exist
• The dispute is purely contractual or commercial
• No public interest element is involved
• The body neither receives State funding nor operates under State control

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Practical Implications For Private Bodies

Private entities performing public functions must:

• Ensure procedural fairness in decision-making
• Provide reasons for adverse decisions
• Comply with principles of natural justice
• Avoid arbitrary or discriminatory practices
• Maintain transparency in operations affecting public interest

For Litigants

When approaching courts against private bodies, litigants should:

• Establish the public function element
• Demonstrate State connection if any
• Show absence of adequate alternative remedies
• Establish violation of constitutional or statutory rights
• Prove substantial public interest involvement

For Courts

Courts must undertake:

• Careful examination of the nature of functions performed
• Balancing of public accountability with private autonomy
• Assessment of whether alternative remedies are adequate
• Consideration of the degree of State involvement
• Analysis of the impact on public interest

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Conclusion

The Indian judiciary has successfully evolved a pragmatic approach to writ jurisdiction against private bodies, balancing the need for constitutional accountability with respect for private autonomy. The functional test focusing on the nature of duties performed, rather than rigid formalistic classifications, represents a progressive and flexible jurisprudence responsive to contemporary realities.

The doctrine continues to evolve, with courts addressing new challenges posed by privatization, digitalization, and complex public-private partnerships. The underlying principle remains constant: wherever power is exercised affecting citizens’ rights and public interest, constitutional safeguards must apply, regardless of whether the entity is formally public or private.

The key is maintaining vigilance against abuse of power while respecting legitimate private enterprise and contractual freedom. As Justice V.R. Krishna Iyer observed in Maneka Gandhi v. Union of India, (1978) 1 SCC 248:

“The Constitution is not for the State alone but for the people, and wherever power is located, constitutional values must conform its exercise.”

Bibliography of Key Cases

1. Ajay Hasia v. Khalid Mujib Sehravardi, (1981) 1 SCC 722
2. Anadi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsav Smarak Trust v. V.R. Rudani, (1989) 2 SCC 691
3. Anuradha Bhasin v. Union of India, (2020) 3 SCC 637
4. Bihar State Cooperative Bank Ltd. v. Shree Hari Chandra Prasad Singh, (2009) 16 SCC 559
5. Binny Ltd. v. V. Sadasivan, (2005) 6 SCC 657
6. Board of Control for Cricket in India v. Cricket Association of Bihar, (2015) 3 SCC 251
7. Central Inland Water Transport Corporation v. Brojo Nath Ganguly, (1986) 3 SCC 156
8. Electricity Board, Rajasthan v. Mohan Lal, (1967) 3 SCR 377
9. Federal Bank Ltd. v. Sagar Thomas, (2003) 10 SCC 733
10. Indian Olympic Association v. Veeresh Malik, (2011) 4 SCC 778
11. Islamic Academy of Education v. State of Karnataka, (2003) 6 SCC 697
12. J.P. Unnikrishnan v. State of Andhra Pradesh, (1993) 1 SCC 645
13. M.C. Mehta v. Kamal Nath, (1997) 1 SCC 388
14. M.I. Builders Pvt. Ltd. v. Radhey Shyam Sahu, (1999) 6 SCC 464
15. Maneka Gandhi v. Union of India, (1978) 1 SCC 248
16. Mathew Ignitious C. v. Catholic Syrian Bank Limited, (2019) 5 KHC 835
17. Naresh Shridhar Mirajkar v. State of Maharashtra, AIR 1967 SC 1
18. Pradeep Kumar Biswas v. Indian Institute of Chemical Biology, (2002) 5 SCC 111
19. R.D. Shetty v. International Airport Authority, (1979) 3 SCC 489
20. S. Shobha v. Muthoot Finance Ltd., 2025 INSC 117
21. Shreya Singhal v. Union of India, (2015) 5 SCC 1
22. Som Prakash Rekhi v. Union of India, (1981) 1 SCC 449
23. State Bank of Patiala v. S.K. Sharma, (1996) 3 SCC 364
24. Sukhdev Singh v. Bhagatram Sardar Singh Raghuvanshi, (1975) 1 SCC 421
25. T.M.A. Pai Foundation v. State of Karnataka, (2002) 8 SCC 481
26. The Authorised Officer, South Indian Bank Ltd. v. Sheela Francis Parakkal, W.A. No. 1498 of 2025 (Kerala High Court)
27. University of Delhi v. Ram Nath, AIR 1963 SC 1873
28. Whirlpool Corporation v. Registrar of Trade Marks, (1998) 8 SCC 1
29. Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649
30. Zoroastrian Co-operative Housing Society Ltd. v. District Registrar Co-operative Societies (Urban), (2005) 5 SCC 632