State of Karnataka v Union of India
Rule established
The Commissions of Inquiry Act is constitutionally valid; a Commission appointed by the Union may inquire into state government conduct where the subject relates to a Union legislative entry; natural justice must be followed.
Facts
- The Union Government appointed a Commission of Inquiry to investigate the conduct of the Karnataka State Government, including its Chief Minister
- Karnataka challenged the appointment as unconstitutional: the Union could not investigate a state government
- Central question: the reach of Union inquiry power over state governments
Issues
- Can the Union Government appoint a Commission of Inquiry to investigate the conduct of a state government?
- Is the Commissions of Inquiry Act constitutionally valid?
- Are natural justice requirements applicable to Commission proceedings?
Held
- The Supreme Court upheld the Act and the Commission's appointment. The Union may appoint a Commission to inquire into matters of public importance even when those matters involve state government conduct, provided the subject relates to a Union legislative entry or a matter of national importance. The Commission's report remains advisory. The state government must be given natural justice: notice and opportunity to respond before adverse findings are made.
Ratio Decidendi
Commissions of Inquiry are valid investigatory mechanisms. The Union's power to appoint a Commission is not limited to Union government conduct. Reports are advisory only and do not impose legal liability. Natural justice applies: persons and entities adversely mentioned must be heard.
How to use it in an exam
Deploy in ADM-5.10 (Commissions of Inquiry) to establish: (i) constitutional validity of the Act; (ii) scope of Union power to investigate state conduct; (iii) advisory nature of the report; (iv) natural justice requirements.
Source
Source: AIR 1977 Supreme Court 1361
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.