In a significant ruling on legislative power and property rights, the Supreme Court set aside a Bihar law that allowed the State Government to take over the Smt. Radhika Sinha Institute and Sachchidanand Sinha Library in Patna.
The Court held that the Smt. Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 was manifestly arbitrary and violative of Article 14 of the Constitution, and therefore unconstitutional.
Read also:- Chhattisgarh High Court Quashes Criminal Complaint Against Judges, Says Allegations Based
A bench of Justice Vikram Nath and Justice Sandeep Mehta delivered the judgment on 10 March 2026, restoring control of the historic institution to its original trust.
Background of the Case
The dispute revolved around the Smt. Radhika Sinha Institute and Sachchidanand Sinha Library, a historic institution established in 1924 by prominent public figure Sachchidanand Sinha, who had served as the first interim President of the Constituent Assembly.
The institute and library were created in memory of his wife, Smt. Radhika Sinha, with funds generated from the sale of ancestral property and a large personal donation of around 10,000 books.
A formal Trust Deed was executed in 1926, under which trustees managed the institution. The deed also provided that the eldest male member of the family would act as Honorary Secretary and Chief Executive Officer.
Read also:- Supreme Court Grants Anticipatory Bail To Folk Singer Neha Singh Rathore In FIR Over Posts On PM
The present appellant, Anurag Krishna Sinha, is the great-grandson of the settlor and currently holds that position in the trust.
In 2015, the Bihar Legislature enacted a law enabling the State Government to take over the institute and dissolve the trust structure, prompting the appellant to challenge the law before the Patna High Court.
The High Court upheld the validity of the law in 2024, leading to the appeal before the Supreme Court.
Key Legal Issues Before the Court
The Supreme Court examined two central questions:
- Whether the 2015 Act was arbitrary and violative of Article 14 of the Constitution.
- Whether the law resulted in confiscatory acquisition of property, violating Article 300A.
Read also:- Kerala High Court Quashes Ombudsman Proceedings Against Village Officer, Says He Is Not
Court’s Observations
The Court noted that the institute had functioned for nearly a century under the trust arrangement without any proven instance of mismanagement.
Importantly, the bench observed that the State Government had not produced any material showing failure of the trust or necessity for takeover.
The Court remarked:
“There is not a single communication from the State Government to the Trust bringing to its notice any allegation of mismanagement, financial irregularity, neglect, or failure to discharge the objects of the Trust.”
The bench said that such a sweeping legislative takeover could not be justified merely on the ground of “better management and development.”
It further pointed out that the law completely dissolved the trust structure and vested all rights in the State, even though less intrusive alternatives were available.
According to the Court, the State could have supported the institution through grants, supervision, or regulatory oversight without resorting to complete acquisition.
Compensation Provision Criticised
Another provision of the law allowed the State Government to pay compensation up to a maximum of one rupee after examining claims.
The Court found this provision highly problematic.
“A statutory provision that enables acquisition of property while reducing compensation to a token amount lacks the basic attributes of fairness.”
The bench held that such a scheme effectively allowed confiscation of property, which cannot pass constitutional scrutiny.
Read also:- Himachal Pradesh High Court Upholds Termination of Power Board Worker Over Matric Certificate from
Supreme Court’s Decision
After analysing the scheme of the law, the Supreme Court concluded that the legislation suffered from manifest arbitrariness.
The Court declared:
“The Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is manifestly arbitrary and violative of Article 14 of the Constitution of India.”
Accordingly, the Court:
- Set aside the Patna High Court judgment dated 29 February 2024, and
- Declared the 2015 Bihar Act unconstitutional.
As a result, the trust governing the institute and library stands restored to its original legal position, with full rights of management and administration.
Case Title: Anurag Krishna Sinha v. State of Bihar & Anr.
Case No.: Civil Appeal No. 13581 of 2025
Decision Date: 10 March 2026
