Electricity Board of Rajasthan v. Mohan Lal

Citation– AIR 1967 SC 1857; 1967 SCR (3) 377
Bench- 5- judges bench (Constitutional Bench)
Facts– The Rajasthan State Electricity Board was a corporate body that had been established under an Act (the Electricity (Supply) Act, 1948), for the purposes of providing electricity in the State of Rajasthan. The case was concerned a disagreement of promotion between the workmen and the State Electricity Commission of Rajasthan. The arguments were presented before the court in Articles 14 and 16 and, therefore, the first and foremost issue which the Court had to decide was whether the Board came under the scope of Section- 3 of The Electricity (Supply) Act, 1948 by merit of fact that it was a other authority under Article 12.
Judgment– The Supreme Court rejected to apply the rule of “ejusdem generis”, by stating that there was no common “genus” under Article 12. The Supreme Court held that the expression ‘other authorities’ is wide enough to include all authorities created by the Constitution or statute on whom powers are conferred by law. In effect, this case has also overruled the decision of holding a university not to be a ‘State’ given by Madras High Court in Santa Bai’s case.

Akanksha Gupta

Currently pursuing LLM from University of Rajasthan. one can reach out her on aklawyerslawhub@gmail.com

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