Centre-state relations in administrative law
Centre-State Relations in Administrative Law
Overview
India is a federal country with a division of powers between the Central Government and the State Governments as laid down in the Constitution of India. The relationship between the Centre and States is governed by constitutional provisions, legislative competencies, and administrative control mechanisms.
Administrative Law Aspect
Centre-State relations in administrative law revolve around how administrative powers are distributed, exercised, and controlled between these two levels of government. This includes issues like:
Legislative competence: Who can legislate on what subjects (Union List, State List, Concurrent List).
Administrative control and interference: Can the Centre control State administrative machinery and vice versa?
Inter-governmental disputes: Resolving conflicts between laws or administrative actions of the Centre and States.
Financial relations: Distribution of resources and grants.
Emergency provisions: How Centre can assume control over State administration during emergencies.
Constitutional Provisions Related to Centre-State Relations
Article 246: Division of legislative powers.
Article 256 & 257: Executive power of the Centre and States; Centre's power to give directions to States.
Article 258: Transfer of functions.
Article 262: Inter-State water disputes.
Article 356: President’s Rule (emergency power).
Article 365: Obligation of States to comply with Centre’s directions.
Important Case Laws on Centre-State Relations in Administrative Law
Case 1: State of Rajasthan v. Union of India, AIR 1977 SC 1361
Context:
This case involved the scope of the Centre’s power under Article 356 (President’s Rule) to dismiss a State government.
Key Points:
The Supreme Court held that the President’s satisfaction under Article 356 must be based on relevant and credible material.
The power is subject to judicial review; it cannot be exercised arbitrarily.
This case protects the autonomy of States against arbitrary dismissal and ensures Centre-State relations are maintained within constitutional limits.
Case 2: S.R. Bommai v. Union of India, (1994) 3 SCC 1
Context:
The most landmark case on federalism and Centre-State relations concerning the misuse of Article 356.
Key Points:
The Court held that the power of the Centre to dismiss State governments is not absolute.
President’s satisfaction is subject to judicial review and must be based on valid grounds.
The concept of “secularism” is a basic feature of the Constitution and violation of which can justify dismissal.
It reinforced federalism and autonomy of States as fundamental constitutional principles.
The case set strict guidelines for imposition of President’s Rule.
Case 3: Rameshwar Prasad v. Union of India, (2006) 2 SCC 1
Context:
Challenged the imposition of President’s Rule in Bihar.
Key Points:
The Supreme Court reiterated the principles of S.R. Bommai.
It held that failure of constitutional machinery in a State must be real and substantiated.
Courts can examine the material on which the President’s satisfaction is based.
Emphasized judicial oversight on Centre’s power in Centre-State administrative relations.
Case 4: In Re: Berubari Union Case, AIR 1960 SC 845
Context:
Related to the power of the Centre to cede territory and implications for State boundaries.
Key Points:
The Court ruled that Parliament can cede territory under Article 368 by amending the Constitution.
If the cession affects State boundaries or powers, the affected State’s consent or a constitutional amendment is required.
This case clarified the limits of Centre’s power in matters affecting States’ territory and autonomy.
Case 5: T.M.A. Pai Foundation v. State of Karnataka, (2002) 8 SCC 481
Context:
Although primarily an education case, it deals with Centre-State powers in regulating educational institutions.
Key Points:
The Supreme Court held that States have regulatory powers but must respect the fundamental rights guaranteed by the Constitution.
It clarified that both Centre and States have roles in education under the Concurrent List.
The decision underscored cooperative federalism in administrative regulation.
Summary
The Constitution provides a clear division of powers but also mechanisms for cooperation and control between Centre and States.
Administrative law principles ensure the Centre respects the autonomy of States, especially regarding dismissal of State governments.
Judicial review acts as a crucial check on arbitrary exercise of Centre’s power.
Landmark cases like S.R. Bommai protect federalism as a basic structure and maintain balance in Centre-State relations.
Cooperation and judicial oversight ensure harmonious administrative functioning within the federal framework.
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