Bombay High Court Rules Bar Associations Are Not "State" Under Article 12

The Bombay High Court held that Bar Associations do not qualify as “State” under Article 12 of the Constitution.

The petition challenged a Kolhapur Bar Association notice denying voting rights to members who hadn’t paid fees. The Court ruled that such associations, being registered societies or trusts, are governed by their own byelaws. 

The court warned that classifying them as “State” would subject internal matters to writ jurisdiction under Article 226, causing administrative chaos.

The bench dismissed the petition and emphasized that professional associations can't be dragged into judicial review over every internal dispute.