Question

In State of Karnataka Vs Union of India AIR 1978 SC 68, Appointment of a commission by the Union government under S. 3(1) of the Commission of Inquiry Act (60 of 1952) to look into the charges of corruption etc against the Chief Minister and other Ministers of a state was challenged. It was held,

• A. Arbitrary under Art.14
• B. Violates federal principle
• C. Jurisdiction of the Court is ousted and hence violates the Basic Structure of the Constitution
• D. Federal Structure is not jeopardized.

Hint:

This case is a key authority that defines Indian federalism as 'cooperative' rather than 'dual'. It establishes that the Centre has a role in ensuring good governance and probing corruption even within states, without this being seen as a violation of the federal principle.

Answer 1

The Correct Option is D

The key here is not to confuse the challenge raised in the case with what the Court actually decided.

1. Identify the challenge: The commission's appointment was attacked on the ground that it violated the federal principle by letting the Centre probe a state government's affairs.
2. Identify the outcome: The seven-judge bench rejected that challenge, holding that fact-finding inquiries into corruption are a matter of national concern and do not amount to the Centre taking over state functions, so the federal structure remains intact.
3. Eliminate the mismatched options: Article 14 arbitrariness and ouster of court jurisdiction were never the grounds of challenge or the basis of decision in this case, and "violates federal principle" describes the rejected argument, not the Court's actual conclusion.

The correct answer is Federal Structure is not jeopardized.

Answer 2

It also helps to think about the practical reasoning the Court used, distinguishing a fact-finding inquiry from actual interference in governance.

1. Arbitrary under Art.14: Nothing in the case turns on unequal treatment; the commission was appointed under a general statute, the Commissions of Inquiry Act, applicable uniformly, so Article 14 arbitrariness was never the basis of the challenge or the decision.
2. Violates federal principle: The Court specifically reasoned that an inquiry is only a fact-finding exercise, not an exercise of executive or legislative power over the state, and concluded that this kind of limited inquiry does not amount to federal interference, directly rejecting this proposition.
3. Jurisdiction of the Court is ousted and hence violates the Basic Structure: No question of excluding courts from reviewing anything arose in this case; the commission's own proceedings remained subject to ordinary legal safeguards, so this option describes a controversy the case did not involve.
4. Federal Structure is not jeopardized: Because a commission of inquiry only gathers facts and makes no binding orders altering the state's executive authority, the Court concluded that the constitutional balance between the Centre and the states remains undisturbed.

Tracing the Court's own reasoning about the limited, fact-finding character of the commission confirms the actual holding.

So, the correct answer is Federal Structure is not jeopardized.