M/S. ZEE TELEFILMS LTD. vs UNION OF INDIA .

The Supreme Court addressed the maintainability of a petition against the Board of Control for Cricket in India (BCCI) under Article 32 of the Constitution, determining that the BCCI does not qualify as a 'State' under Article 12. The Court relied on the precedent set in Pradeep Kumar Biswas vs. Indian Institute of Chemical Biology & Ors. (2002 5 SCC 111), affirming that the BCCI, being an autonomous body registered under the Societies Registration Act, does not exercise governmental functions nor is it controlled by the government. Consequently, the petition was deemed not maintainable, leading to its dismissal.