S.S. RANA vs REGISTRAR, COOPERATIVE SOCIEITES

The Supreme Court held that the Kangra Central Co-operative Bank Ltd is not a 'State' under Article 12 of the Constitution of India, affirming the High Court's dismissal of the writ petition. The Court emphasized that the State's control over the Society was not deep and pervasive, as it could only appoint one out of three directors, and the Board's decisions were final. The Court also noted that the principles of natural justice were not violated in the disciplinary proceedings against the petitioner, as the inquiry report was not required to be shared with him under the applicable rules.