State of Rajasthan & Ors vs Union of India
🧑⚖️ State of Rajasthan & Ors vs Union of India
Citation: AIR 1977 SC 1361
Court: Supreme Court of India
Bench: Justice V.R. Krishna Iyer, Justice P.N. Bhagwati, Justice K.N. Singh
Date of Judgment: 14 July 1977
⚖️ Facts of the Case
During a period of scarcity and emergency, the Union of India passed orders under the Essential Commodities Act, 1955 and other statutes to regulate the distribution of essential commodities like food grains.
The States of Rajasthan and others challenged these orders, claiming the Union was acting ultra vires and interfering in the states’ domain.
The States argued that the Union did not have authority to regulate and distribute goods within the state boundaries, violating federal principles.
The Union contended that it was acting under its constitutional powers to ensure equitable distribution during emergency conditions.
⚖️ Legal Issues
Whether the Union Government has the power to regulate the distribution of essential commodities within States during emergency or scarcity.
Whether such action violates the federal structure and the distribution of powers under the Constitution.
The scope of Union's powers under Article 249 and Essential Commodities Act.
The balance between Union’s directive powers and States' autonomy.
🏛️ Supreme Court Judgment
✔️ Key Observations
Union’s powers during emergency:
The Union has wide powers to regulate essential commodities under the Essential Commodities Act, 1955.
During emergency or scarcity, the Union can intervene to ensure equitable distribution of resources.
Federal structure and cooperative federalism:
The court emphasized the need for cooperation between Union and States.
Federalism is not a rigid division but a flexible distribution of powers allowing Union to act in the larger public interest.
Constitutional provisions invoked:
The Court upheld the use of Article 249 (power of Parliament to legislate on matters in the State List during public interest).
Also upheld the Union’s authority under the Essential Commodities Act to ensure supply chain integrity.
Balancing rights and duties:
The Court balanced the States’ rights with the Union’s responsibility to maintain public order and economic stability.
Held that Union's action was not ultra vires and in fact necessary.
🧩 Ratio Decidendi
The Union Government can regulate the distribution of essential commodities even within States during emergency/scarcity.
Such regulation is not unconstitutional and does not infringe on States' rights if done under valid constitutional powers.
The case upholds the principle of cooperative federalism, especially in times of crisis.
The Constitution allows flexibility to meet the public interest and welfare needs beyond strict federalism.
⚖️ Significance
Important precedent for Union-State relations in India.
Clarifies the scope of Union’s legislative powers under emergency or extraordinary circumstances.
Recognizes the principle of cooperative federalism over rigid federalism.
Gives a framework for handling essential commodities distribution and economic emergencies.
🔍 Related Case Law
State of West Bengal v. Union of India (1963) AIR 1241 – On emergency powers of Union.
R.C. Cooper v. Union of India (1970) AIR 564 – On federalism and emergency.
K.C. Gajapati Narayan Deo v. State of Orissa (1953) SCR 176 – On legislative powers.
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