In Anurag Krishna Sinha vs. The State of Bihar & Anr. (2026), Supreme Court's Division Bench of Justices Vikram Nath and Sandeep Mehta delivered a 37-page long judgement dated March 10, 2026, wherein, it concluded:"The impugned Act authorises the State to take over the Institute & Library in its entirety, dissolving existing legal arrangements and divesting long-standing rights, without any demonstrated necessity, objective criteria, or prior inquiry. The manner in which this power is exercised is excessive, unreasoned and disproportionate to the stated object of 'better management and development'. We are therefore satisfied that the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is manifestly arbitrary and violative of Article 14 of the Constitution of India."
Justice Vikram Nath authored the judgement. The judgement reads:"....the scheme of the Act permits deprivation of property without adherence to basic requirements of fairness and due process. The absence of any principled or meaningful framework for compensation underscores the arbitrary character of the legislative measure. While Article 300A permits deprivation of property by authority of law, such law must be fair, reasonable and non-confiscatory. The impugned Act fails to meet this standard. 52. In view of the above, the judgment and order dated 29th February 2024 passed by the High Court of Judicature at Patna in Civil Writ Jurisdiction Case No.7940 of 2015 is set aside. The Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is declared unconstitutional and is accordingly struck down. 53. Accordingly, the Trust governing the Institute & Library, together with its rights of management and administration, shall stand restored to its pre-existing legal position prior to the enactment of the impugned Act. This shall not preclude the State Government from providing financial assistance, administrative support or regulatory oversight in accordance with law. 54. The appeal is accordingly allowed."
The Court appeal arose on i. Whether the Smt. Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 is manifestly arbitrary and violative of Article 14 of the Constitution of India. ii. Whether the impugned Act effects compulsory acquisition and extinguishment of rights in a confiscatory manner, thereby offending Article 300A read with Article 14 of the Constitution of India.
The Court heard the appeal which challenged 37-page long judgment dated February 29, 2024 passed by Chief Justice K. Vinod Chandran and Justice Rajiv Roy of the Patna High Court in Anurag Krishna Sinha vs. The State of Bihar through the Chief Secretary, Government of Bihar & Anr. (2024), whereby the appellant’s writ petition was dismissed by the High Court while upholding the validity of the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015. The respondent no. 2 was the Secretary, Department of Law, Government of Bihar. The High Court's judgment was authored by Justice Chandran.
Notably, the Institute & Library were established in 1924 by Sachichidanand Sinha, a distinguished public figure of Bihar, who served as the first President of the Constituent Assembly for an interim period. The Institute & Library was founded in memory of his wife, Radhika Sinha. For this purpose, Sachichidanand Sinha had addressed a letter to the then Governor of Bihar and Orissa, offering a sum of ₹50,000 from the sale proceeds of ancestral property belonging to Radhika Sinha. The offer was accepted, and the foundation stone was laid on March 28, 1922. The construction of the buildings for the Institute and Library was completed using the money.
Justice Chandran had concluded:"46. The vesting occurs of ‘the Institute & Library’ on the State Government for the purpose of better management and development of ‘the Institute & Library’. The objects of the Trust cannot be digressed from by the State Government nor is it intended to be, as is disclosed from the impugned enactment. Whatever rights, powers and duties that remained with the Trustees, in the management of ‘the Institute & Library’ as was available after Annexure-2 agreement was entered into, would also vest completely in the State Government by the impugned enactment. 47. We find absolutely no reason to entertain the writ petition and dismiss the same but hasten to add that the vesting does not absolve the State Government from carrying on the objects of the Trust; which obligation attaches itself to the Trust taken over by the State Government, intention of the original settlor. 48. The writ petition stands dismissed without any order on costs." His conclusion has been set aside and the Supreme Court declared the Smt. Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 to be unconstitutional, and has been accordingly struck down.
Also read: Constitutionality of Srimati Radhika Sinha Institute and Sachidanand Sinha Library (Requisition And Management) Act, 2015 remains sub judice
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