STATE OF KERALA vs GENERAL MANAGER, SOUTHERN RAILWAY, MADRAS

The Supreme Court held that under Section 80 of the Code of Civil Procedure, a suit against the railway administration must include the Union of India as a defendant, as the Southern Railway is owned by the Union. The Court overruled the precedent set in Dominion of India v. Firm Musaram Kishunprasad, clarifying that railway administrations do not possess separate legal personality for civil suits. Consequently, the appeal was dismissed, affirming the lower courts' decisions.