Virendra Kumar Srivastava vs U.P. Rajya Karmachari Kal. Nigam And ...

The Supreme Court held that U.P. Rajya Karmachari Kalyan Nigam is not covered by the definition of 'State' under Article 12 of the Constitution of India, thus not amenable to writ jurisdiction under Article 226. The Court relied on the multiple test established in Pradeep Kumar Biswas vs. Indian Institute of Chemical Biology, which requires a body to be financially, functionally, and administratively dominated by the Government to qualify as 'State'. The appeal was dismissed, affirming the High Court's decision that the Corporation's control was merely regulatory.