Pradeep Kumar Biswas & Ors vs Indian Institute Of Chemical Biology & ...

The Supreme Court held that the Council for Scientific and Industrial Research (CSIR) does not qualify as 'the State' under Article 12 of the Constitution, thereby overruling the precedent set in Sabhajit Tewary's case. The Court emphasized the need to distinguish between an instrumentality of the State and other authorities, clarifying that being classified as 'the State' under Article 12 does not automatically confer protections under Articles 309, 310, and 311. The judgment reaffirms the principles governing the definition of 'the State' and its implications for fundamental rights.