Y.L. Ahuja vs Institute Of Applied Manpower And ... on 18 September, 1995
Chief Justice, in Sukhdev Singh Vs. Bhagat Ram we would for reasons already discussed, prefer to adopt the test of governmental instrumentality or agency as .one more test and perhaps a more satisfactory one for determining whether a statutory corporation, body or other authority falls within the definition of "State". If a statutory corporation, body or other authority is an instrumentality or agency of government, it would be an 'authority' and, therefore, "State" within the meaning of that expression in Article 12".