On 4 May 1979, a three-judge Bench led by Justice P.N. Bhagwati laid down the multi-factor 'instrumentality or agency' test for when a body is 'State' under Article 12, and held that the State and its instrumentalities cannot depart arbitrarily from their own self-imposed standards when awarding contracts and largesse.
On 7 April 2026 the Competition Commission held seventeen electrical contractors liable under s.3(3)(d) for cover bidding and bid rotation in APHCL tenders, but issued only a cease-and-desist direction under s.27(a) — calibrating contravention-finding against penalty-quantum where the contraveners are small enterprises with geographically circumscribed conduct.