Manifest Arbitrariness: Anurag Krishna Sinha v. State of Bihar (2026)

When a legislature reaches into the affairs of a single, named, still-functioning institution and hands its entire property and governance over to the State, the question is not merely whether the State may acquire property. It is whether the law that does so can survive the discipline of Article 14. In Anurag Krishna Sinha v. State of Bihar, a Division Bench of Justice Vikram Nath and Justice Sandeep Mehta answered that question by striking down the enabling statute as unconstitutional in both conception and operation.

The facts in brief

At the centre of the case is the Sachchidanand Sinha Library, together with the Srimati Radhika Sinha Institute — a heritage institution established in 1924 by Dr. Sachchidanand Sinha, who served as the first, provisional President of the Constituent Assembly of India. For close to a century the institution functioned under a governing trust.

In 2015, the Bihar legislature enacted the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015. The Act dissolved the governing trust and vested the management and property of the institution in the State Government. Section 7 of the Act capped compensation for this takeover at a maximum of one rupee.

The takeover was challenged. The Patna High Court upheld the Act on 29 February 2024. The matter then reached the Supreme Court by way of Civil Appeal No. 13581 of 2025.

The questions

The appeal placed two related questions before the Court. First, whether a legislature may single out one named, functioning private or charitable institution for complete vesting of its property and dissolution of its trust in the State, absent any finding that the institution was mismanaged or that the takeover was necessary. Second, whether a statutory scheme that fixes compensation for such a takeover at a maximum of one rupee, and that offers no guiding principles or safeguards, can withstand scrutiny under Article 14.

What the Court held

The Supreme Court allowed the appeal. It struck down the 2015 Act as unconstitutional, and restored the trust's management and administration of the institution to its pre-2015 position.

The Court reached that result by applying the manifest-arbitrariness standard articulated in Shayara Bano v. Union of India. It did not isolate a single defect and rest the judgment on it. Instead, it read the statute's features cumulatively. The complete vesting of the property; the dissolution of long-standing trust arrangements; the absence of any demonstrated necessity or mismanagement; compensation that was illusory rather than real; and the want of any intelligible basis for selecting a single institution among several deteriorating public libraries — taken together, these features rendered the enactment manifestly arbitrary, and therefore void under Article 14.

The compensation provision drew particular attention. A ceiling of one rupee is not compensation in any meaningful sense; it is the formal appearance of compensation with none of its substance. A scheme that takes the whole of an institution's property while offering a token in return does not satisfy the law's demand that State action affecting property rest on a fair and intelligible basis.

Manifest arbitrariness as the governing test

The significance of Anurag Krishna Sinha lies in how it deploys the manifest-arbitrariness doctrine. Shayara Bano established that a law may fall foul of Article 14 not only when it draws an irrational classification, but when it is itself arbitrary — capricious, irrational, or without adequate determining principle, or excessive and disproportionate. That standard, originally applied to invalidate the practice of instantaneous triple talaq, is here turned on a piece of primary legislation that takes over a charitable institution.

The Court's method is instructive. Manifest arbitrariness is not established by pointing to one stray flaw. It is established by reading the statute as a whole and asking whether the cumulative design discloses any determining principle at all. Here it did not. There was no finding of necessity. There was no finding of mismanagement that the takeover was meant to cure. There were no guiding principles to channel the exercise of the power, and no safeguards to discipline it. And there was no reason, intelligible on the face of the scheme, why this one institution — rather than any of the several other deteriorating public libraries — should be singled out for vesting and dissolution.

Singling out a single institution

The selection of one named institution is the feature that ties the analysis together. A general law for the preservation or management of deteriorating public libraries would raise different questions. A statute that names one functioning institution, dissolves its century-old trust, vests its property in the State, and offers a rupee in exchange, invites the inference that the law is not pursuing any coherent public purpose at all. The absence of an intelligible basis for the singling-out is, in the Court's reading, of a piece with the absence of necessity, the absence of safeguards, and the illusory compensation. Each gap reinforces the others.

The remedy followed the diagnosis. Because the defect lay in the conception and operation of the statute itself, the Court did not attempt to read down or sever. It struck the Act down and restored the status quo ante, returning management and administration of the institution to the trust as it stood before 2015.

Why it matters

Anurag Krishna Sinha is a working demonstration of manifest arbitrariness applied to property-affecting legislation. It confirms that Article 14 polices not only the classifications a legislature draws but the substance and design of the law itself — and that a statute may be void for arbitrariness even where the State's competence to legislate is not in doubt.

For institutions held in trust, the judgment is a meaningful protection. A legislature that wishes to take over a functioning charitable or heritage institution must be able to point to a determining principle: a demonstrated necessity, a finding of mismanagement, guiding standards, safeguards, and real compensation. A scheme that supplies none of these, and that targets a single named institution, will not survive. The one-rupee ceiling is the case's enduring image — a reminder that the appearance of compensation is not the same as compensation, and that the courts will look past the form of a statute to its operation.

Related on Valkya

• Shayara Bano v. Union of India
• Maneka Gandhi v. Union of India
• DDA v. Tejpal — Section 24(2) land acquisition lapse
• Property Owners Association v. State of Maharashtra

Sources

• LiveLaw — SC quashes Bihar Act to take over historic library at Rs 1
• Verdictum — Anurag Krishna Sinha v. State of Bihar, 2026 INSC 219
• LiveLaw — 2026 LiveLaw (SC) 226