PRADEEP KUMAR BISWAS vs INDIAN INSTITUTE OF CHEMICAL BIOLOGY&ORS

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 or agency of the State and other authorities, asserting that the definition of 'the State' in Article 12 is specifically for the application of fundamental rights and does not automatically extend protections under Articles 309, 310, and 311. The judgment clarifies that being classified as 'the State' does not confer all constitutional protections to its employees under Part XIV of the Constitution.