Lucknow Development Authority vs Union of India & Ors
Supreme Court Remits 25-Year-Old Writ Petition, Holds Article 131 Not Applicable to Statutory Authorities
Case Snapshot
Case Name: Lucknow Development Authority v. Union of India & Ors.
Citation: 2026 INSC 923
Bench: Justice Dipankar Datta and Justice Sheel Nagu
Date of Judgment: August 21, 2026
Area of Law: Constitutional Law, Writ Jurisdiction, Article 131, Administrative Law
The Judgment in One Line
Statutory authority like Lucknow Development Authority is not a "State" under Article 131; High Court's dismissal for Article 131 remedy was erroneous.
Why This Judgment Matters
This judgment is significant as it clarifies the distinction between "State" under Article 12 (which includes instrumentalities of the State) and "State" under Article 131 (which refers only to constituent States in the First Schedule). The Supreme Court held that a statutory authority like the Lucknow Development Authority cannot be directed to approach this Court under Article 131, as Article 131's original jurisdiction is confined to disputes between the Government of India and one or more States. The Court also deprecated the High Court's approach of dismissing a writ petition pending for nearly 25 years on such an untenable ground, directing expeditious disposal on merits.
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