The Supreme Court declared the Bihar law enabling the takeover of Patna’s historic Sinha Library unconstitutional, calling the Rs 1 compensation “illusory” and arbitrary. The Court ordered that the management of the nearly century-old library be restored to the original trust.
The Supreme Court of India has struck down a Bihar law that allowed the State government to take control of a historic library in Patna, ruling that the legislation was unconstitutional and unfair. The Court said that the law permitted the State to acquire the institution by paying only a token compensation of ₹1, which it described as unreasonable and lacking fairness.
A bench comprising Justices Vikram Nath and Sandeep Mehta delivered the verdict while hearing a challenge to the State’s takeover of the historic Sachchidanand Sinha Library. The Court set aside a 2024 judgment of the Patna High Court that had earlier upheld the acquisition by the State government.
While striking down the law, the bench clearly declared,
“The Srimati Radhika Sinha Institute and Sachchidanand Sinha Library Act, 2015 is declared unconstitutional and is accordingly struck down.”
The Court further directed that the management and administration of the historic library must be handed back to the original trust that had been running the institution for decades.
The library, located in the heart of Patna, is a well-known cultural and intellectual landmark. The two-storey building is widely known as the Sinha Library and has played an important role in the academic and cultural life of Bihar for nearly a century.
During the hearing, the Supreme Court closely examined the process followed by the State government before passing the law that enabled the takeover. The Court found serious flaws in the State’s actions. According to the judgment, there was no evidence that the government had communicated any concerns to the trust regarding the management of the institution.
The Court noted that there was not a single official communication sent by the government to the trust or its trustees informing them about alleged mismanagement, financial irregularities, negligence, or failure to fulfil the objectives of the trust. This lack of communication raised serious questions about the justification for such a drastic step.
The bench also pointed out that the government had failed to provide any valid reason for acquiring the library before passing the legislation. Emphasising the seriousness of the issue, the Court said,
“A measure of such sweeping consequence, including complete divestiture of an institution that has functioned for nearly a century, cannot rest on assumptions that were never put to the very persons sought to be displaced. This itself is a powerful indicator of the arbitrary character of the legislative action.”
Another major concern raised by the Supreme Court was the compensation clause in the law. Section 7 of the Act allowed the State to pay compensation of up to only one rupee for acquiring the institution. The Court strongly criticised this provision and described it as unjust and arbitrary.
The bench observed,
“While Article 300A of the Constitution permits deprivation of property by authority of law, such law must nevertheless be just, fair and reasonable, and not arbitrary or confiscatory in effect.”
According to the Court, even though the Constitution allows the State to acquire property through legal authority, such laws must still meet basic standards of fairness and reasonableness.
The judges said that allowing the government to acquire a property while offering only a token amount as compensation violated these principles. They noted that such a provision not only gave the legislature excessive power but also reduced compensation to a purely symbolic amount.
The Court therefore concluded that the nature of the acquisition was confiscatory and failed to meet constitutional standards. Criticising the way the law was framed and applied, the bench stated,
“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… Act is manifestly arbitrary and violative of Article 14 of the Constitution.”
The library itself holds deep historical significance. It was founded by Sachchidananda Sinha, one of the prominent architects of modern Bihar. The institution was formally inaugurated on February 9, 1924, by Sir Henry Wheeler, who was then serving as the Governor of Bihar and Orissa.
The institution was officially named the Srimati Radhika Sinha Institute and Sachchidanand Sinha Library, in memory of Sinha’s wife, Radhika Sinha. Over the years, however, it became popularly known simply as the Sinha Library.
Sachchidananda Sinha was also a significant figure in India’s constitutional history. He served as the provisional president of the Constituent Assembly of India when it met in Delhi for the first time in 1946.
Before the State government enacted the 2015 law, the library had been managed by the Srimati Radhika Sinha Institute and Sachchidananda Sinha Library Trust. With the Supreme Court now declaring the takeover law unconstitutional, the Court has ordered that the administration and management of the historic institution must be returned to the original trust.
The ruling is seen as an important reaffirmation of constitutional protections related to property rights and the limits on the State’s power to acquire private or trust property without fair compensation.
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