The Patna High Court has dismissed a writ petition filed by the erstwhile Chairman and Members of the Bihar Sanskrit Education Board, who challenged the Bihar Sanskrit Education Board (Amendment) Act, 2024. The Court upheld the State’s legislative decision to dissolve the Board and to insert an express power enabling dissolution “in larger public interest,” while mandating interim administration and a time-bound reconstitution of the Board. The judgment clarifies how challenges to plenary legislation must cross the high bar of constitutional invalidity—mere hardship to office-holders is not enough.

Simplified Explanation of the Judgment

The petitioners were the Chairman and other Members of the Bihar Sanskrit Education Board constituted under the Bihar Sanskrit Education Board Act, 1981. Their tenure under the 1981 Act was three years from appointment/nomination. In 2024, the State Legislature amended the Act. The amendment (i) dissolved the then-existing Board, (ii) inserted a non-obstante clause empowering the Government to dissolve the Board during its term if satisfied that doing so is in larger public interest to align with the Act’s aims, (iii) provided for an Administrator of at least Secretary rank to manage affairs in the interim, (iv) required constitution of a Committee of Experts to recommend re-organisation consistent with the National Education Policy (NEP) 2020, and (v) obliged the State to constitute a new Board within three months of dissolution. The petitioners argued that this mid-term dissolution was arbitrary, politically motivated, and violated Article 14 of the Constitution.

The Court rejected the challenge. First, it reiterated the presumption of constitutionality: a State law stands unless the challenger shows lack of legislative competence or violation of constitutional provisions. The petitioners did not dispute competence; they urged arbitrariness under Article 14. The Bench explained that after landmark decisions like Maneka Gandhi and later five-Judge pronouncements such as Shayara Bano, “manifest arbitrariness” can be a ground to invalidate legislation—but arbitrariness must be shown with cogent reasons. Here, the petitioners’ primary grievance was only that their ongoing tenure ended abruptly upon dissolution. That, by itself, does not establish arbitrariness in the statute.

Second, the Court examined the 1981 Act’s object: to create an autonomous Board to supervise and develop Sanskrit education up to the Madhyama standard across Bihar. It noted the Board’s functions include recognition of institutions, maintenance of registers, syllabi, examinations, and textbooks—functions aimed at educational advancement. The Court reasoned that the power to constitute a Board generally implies a corresponding power to dissolve it, especially when the statute—now as amended—explicitly authorizes dissolution for larger public interest consistent with the Act’s aims. The amendment, therefore, filled a “lacuna” in the original law, clarifying the State’s authority in a manner tethered to the Act’s purpose.

Third, the Court considered the legislative context recited in the Amendment’s introduction: alignment with NEP 2020 and data from the Bihar Caste-Based Survey Report, 2022–23. This policy backdrop supported a re-organisation/modernisation of Sanskrit education—adding science, humanities, and vocational subjects alongside traditional streams—through an expert committee process and a time-bound reconstitution. The Court held these features evidence a rational legislative design rather than arbitrariness.

Fourth, on the interim arrangement, the petitioners argued that appointing a Secretary-rank Administrator would not advance Sanskrit education. The Court disagreed, noting that the arrangement is temporary, hedged by clear timelines and the requirement to consult an expert committee and reconstitute the Board within three months. The transitory nature avoids a vacuum and keeps administration running while reforms are structured.

Fifth, the Bench distinguished a Division Bench decision (Dr. Ashish Kumar Sinha v. Union of India, 2022(6) BLJ 369), where changes to the municipal statute were found contrary to the scheme of local self-government and constitutional provisions on municipal autonomy. In contrast, the Sanskrit Board’s amendment did not undermine the 1981 Act’s scheme; rather, it sought to better serve its objects. Thus, the cited ruling had no application.

Finally, the Court emphasised that hardship to incumbents—loss of office mid-term—is not a ground to strike down a statute. Constitutional review focuses on competence and consistency with fundamental rights/constitutional provisions. As the petitioners failed to demonstrate “manifest arbitrariness,” the challenge under Article 14 failed. Result: writ petition dismissed; amendments sustained.

Significance or Implication of the Judgment (For general public or government)

For the public, this judgment underscores that educational governance structures may be reorganised by legislation when justified by broader policy goals—here, aligning Sanskrit education with NEP 2020 and modern curricular needs. It clarifies that office-holders of statutory bodies do not possess a vested, indefeasible right to complete their tenure if the statute permits dissolution in public interest. For the State, it affirms that well-structured, purpose-linked amendments—especially those with interim safeguards (Administrator) and time-bound mandates (expert committee and reconstitution)—will likely withstand Article 14 scrutiny. The decision may guide future reforms of boards and councils in Bihar, provided the legislative design remains rational, proportionate, and tethered to the parent Act’s objectives.

Legal Issue(s) Decided and the Court’s Decision with reasoning

• Whether the 2024 amendment dissolving the Sanskrit Education Board and empowering the State to dissolve a Board mid-term violates Article 14 (manifest arbitrariness).
  Decision: No violation. The amendment advances the Act’s purpose, introduces safeguards (Administrator, expert committee, three-month reconstitution), and is justified by policy alignment with NEP 2020; mere termination of incumbents’ tenure is insufficient to prove arbitrariness.
• Whether dissolution and interim administration by a Secretary-rank officer undermines the parent Act.
  Decision: No. The interim setup is temporary and structured; the statute mandates expert input and quick reconstitution, preventing a policy vacuum.
• Whether prior case law on arbitrariness and legislative review supports invalidation.
  Decision: No. The Court applied the “manifest arbitrariness” doctrine (post-Shayara Bano) but found no disproportionality or excessive interference with rights. Presumption of constitutionality was not rebutted.
• Whether a prior Division Bench ruling on municipal governance controls this case.
  Decision: Distinguished. The municipal case turned on local self-government autonomy; here, the amendment does not contradict the parent Act’s scheme and aims.

Judgments Referred by Parties (with citations)

• Shayara Bano v. Union of India, (2017) 9 SCC 1 (on manifest arbitrariness under Article 14).
• State of A.P. v. McDowell & Co., (1996) 3 SCC 709 (considered in Shayara Bano for scope of judicial review).
• Ajay Hasia v. Khalid Mujib Sehravardi, (1981) 1 SCC 722.
• K.R. Lakshmanan v. State of Tamil Nadu, (1996) 2 SCC 226.
• Mohd. Arif v. Registrar, Supreme Court of India, (2014) 9 SCC 737.
• Maneka Gandhi v. Union of India, (1978) 1 SCC 248.
• Ashoka Kumar Thakur v. Union of India, (2008) 6 SCC 1.
• Dr. Ashish Kumar Sinha & Ors. v. Union of India & Ors., 2022(6) BLJ 369 (Patna) (distinguished).

Judgments Relied Upon or Cited by Court (with citations)

• Shayara Bano v. Union of India, (2017) 9 SCC 1 — five-Judge Bench clarifying arbitrariness as a ground under Article 14.
• Ashoka Kumar Thakur v. Union of India, (2008) 6 SCC 1 — on grounds to challenge legislation and presumption of constitutionality.
• Maneka Gandhi v. Union of India, (1978) 1 SCC 248 — Article 21 read with Articles 14 and 19 on reasonableness of “law” and “procedure.”
• Ajay Hasia v. Khalid Mujib Sehravardi, (1981) 1 SCC 722; K.R. Lakshmanan v. State of Tamil Nadu, (1996) 2 SCC 226; Mohd. Arif v. Registrar, Supreme Court of India, (2014) 9 SCC 737 — cited in the Court’s discussion of arbitrariness and constitutional review.

Case Title
Chairman and Members of the Bihar Sanskrit Education Board v. State of Bihar & Ors.

Case Number
Civil Writ Jurisdiction Case No. 7413 of 2024.

Citation(s)
2025 (1) PLJR 269

Coram and Names of Judges — Always prefix with Hon’ble
Hon’ble the Chief Justice K. Vinod Chandran and Hon’ble Mr. Justice Partha Sarthy.

Names of Advocates and who they appeared for

• For the petitioners: Mr. Y.V. Giri, Senior Advocate; Mr. Ashish Giri, Advocate; Mr. Saunil Kumar Jha, Advocate; Ms. Riya Giri, Advocate.
• For the State (Bihar): Mr. P.K. Shahi, Advocate General; Mr. Manish Dhari Singh, AC to AG.
• For the Union of India: Mr. Ram Anurag Singh, Central Government Counsel.

Link to Judgment
MTUjNzQxMyMyMDI0IzEjTg==-loKeTA5yYPY=

If you found this explanation helpful and wish to stay informed about how legal developments may affect your rights in Bihar, you may consider following Samvida Law Associates for more updates.