ANURAG KRISHNA SINHA versus STATE OF BIHAR & ANR.

Citation: [2026] 3 S.C.R. 465 · Decided: 10-03-2026 · Supreme Court of India · Bench: VIKRAM NATH · Disposal: Appeal(s) allowed

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Judgment (excerpt)

[2026] 3 S.C.R. 465 : 2026 INSC 219
Anurag Krishna Sinha 
v. 
State of Bihar & Anr.
(Civil Appeal No. 13581 of 2025)
10 March 2026
[Vikram Nath* and Sandeep Mehta, JJ.]
Issue for Consideration
i) Whether the Smt. Radhika Sinha Institute and Sachchidanand 
Sinha Library (Requisition & Management) Act, 2015 is manifestly 
arbitrary and violative of Article 14 of the Constitution of India;  
ii) 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.
Headnotes†
Constitution of India – Art.14 – Validity of Srimati Radhika 
Sinha Institute and Sachchidanand Sinha Library (Requisition & 
Management) Act, 2015 (impugned Act) – The Institute & Library 
were established in the year 1924 – A formal Deed of Trust was 
executed on 10.03.1926 – On 24.11.1955, an agreement was 
entered into between the Government of Bihar and the Trust, 
whereby the Institute & Library were accorded the status of 
a State Central Library – It was expressly agreed that control 
and management of the institution and its property would 
continue to vest in the trustees, while the State Government 
would provide financial assistance – The State promulgated the 
Smt. Radhika Sinha Institute and Sachichidanand Sinha Library 
(Acquisition and Management) Ordinance, 1983, by which the 
Trust was sought to be acquired and vested in the State – Writ 
petition – The Ordinance was challenged – Ordinances lapsed – 
The High Court rejected the writ petition – The Bihar State 
Legislature enacted the impugned Act – Again, writ petition 
was filed before the High Court, which was dismissed and the 
validity of the Act was upheld – Correctness:
Held: The impugned Act authorises the State to take over 
the Institute & Library in its entirety, dissolving existing legal 
arrangements and divesting long-standing rights, without any 
* Author
466
[2026] 3 S.C.R.
Supreme Court Reports
demonstrated necessity, objective criteria, or prior inquiry – The 
manner in which this power is exercised is excessive, unreasoned 
and disproportionate to the stated object of “better management 
and development” – This Court is of the view that Srimati Radhika 
Sinha Institute and Sachchidanand Sinha Library (Requisition & 
Management) Act, 2015 is manifestly arbitrary and violative of 
Art.14 of the Constitution of India – Further, the scheme of the 
Act permits deprivation of property without adherence to basic 
requirements of fairness and due process – The absence of any 
principled or meaningful framework for compensation underscores 
the arbitrary character of the legislative measure – While Art.300A 
permits deprivation of property by authority of law, such law must 
be fair, reasonable and non-confiscatory – The impugned Act 
fails to meet this standard – The Srimati Radhika Sinha Institute 
and Sachchidanand Sinha Library (Requisition & Management) 
Act, 2015 is unconstitutional and is accordingly struck down – 
Accordingly, the Trust governing the Institute & Library, together 
with its rights of management and administration, shall stand 
restored to its pre-existing legal position prior to the enactment of 
the impugned Act – This shall not preclude the State Government 
from providing financial assistance, administrative support or 
regulatory oversight in accordance with law. [Paras 50-53]
Trust – Public Trust – Determination of legal character:
Held: The fact that an institution is intended to serve a public 
purpose or is open to public use does not, by itself, conclusively 
determine that the trust is a public trust in law – The legal character 
of a trust depends on several factors, including the manner in 
which the dedication is made, the structure of the trust, the nature 
of control and management, and the rights reserved by the Settlor 
and his successors under the trust deed – A public-facing object, 
standing alone, is not determinative. [Para 19]
Constitution of India – Art.14 – Principle of equality – Evolution 
of – Discussed. [Paras 23-34]
Constitution of India – Art.14 – Equality before the law is not 
a mere formal concept:
Held: The guarantee by Art.14 strikes at arbitrariness in State action 
and ensures that the exercise of legislative power is informed by 
reason, fairness and non-discrimination – Equality before the law 
is not a mere formal concept; it embodies the principle that State 
[2026] 3 S.C.R. 
467
Anu

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