M/S. Zee Telefilms Ltd. & Anr vs Union Of India & Ors

The Supreme Court examined whether the Board of Control for Cricket in India qualifies as 'State' under Article 12 of the Constitution. The Court held that the Board, being registered under the Societies Registration Act 1860 and not created by statute, does not fall within the definition of 'State' as it operates autonomously without government control or financial assistance. The judgment reaffirmed the principles established in Pradeep Kumar Biswas vs. Indian Institute of Chemical Biology & Ors. (2002 5 SCC 111), concluding that the Board's monopoly in cricket does not equate to state action under Article 12.