Companies Not 'State' Under Article 12 for Mere Compliance of Rules : Allahabad High Court

The Allahabad high court held that a company’s complying with various rules and regulations established under various ministries does not render it a “State” as defined in Article 12 of the Constitution.

M/s Manoj Petroleum, a Nayara Energy franchiser, was terminated in disciplinary proceedings after a sample from Manoj Petroleum tested by Bharat Petroleum Corporation Ltd. allegedly found violations. 

The company challenged this decision in a writ petition, arguing that it was arbitrary.

The court ruled the dispute was contractual and Nayara Energy was not under state control, making the petition non-maintainable. It advised the petitioner to seek arbitration instead of invoking Article 226.