Question:

In State of Karnataka Vs Union of India AIR 1978 SC 68, Appointment of a commission by the Union government under S. 3(1) of the Commission of Inquiry Act (60 of 1952) to look into the charges of corruption etc against the Chief Minister and other Ministers of a state was challenged. It was held,

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This case is a key authority that defines Indian federalism as 'cooperative' rather than 'dual'. It establishes that the Centre has a role in ensuring good governance and probing corruption even within states, without this being seen as a violation of the federal principle.
Updated On: Oct 31, 2025
  • Arbitrary under Art.14
  • Violates federal principle
  • Jurisdiction of the Court is ousted and hence violates the Basic Structure of the Constitution
  • Federal Structure is not jeopardized.
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The Correct Option is D

Solution and Explanation

Step 1: Understanding the Concept:
The question concerns a landmark case on Indian federalism. The core issue was whether the Central Government could appoint a commission of inquiry to investigate corruption allegations against a State's Chief Minister and other ministers without encroaching upon the State's autonomy, thus violating the federal structure.
Step 2: Detailed Explanation:
In State of Karnataka v. Union of India, a seven-judge bench of the Supreme Court upheld the Central Government's power to appoint such a commission. The court's reasoning was:
1. The scheme of the Indian Constitution is one of cooperative federalism, not of two strictly separate and competing sovereignties.
2. The power of inquiry is a mechanism to ensure purity in public life, which is a matter of national concern.
3. The Commission of Inquiry Act allows the Centre to inquire into any "definite matter of public importance." Corruption at high levels, even within a State, is such a matter.
4. An inquiry is only a fact-finding process and does not amount to the Centre taking over the executive or legislative functions of the State.
Therefore, the Court concluded that the appointment of the commission by the Union Government did not undermine the state's powers and the federal structure was not jeopardized.
Step 3: Final Answer:
It was held that the Federal Structure is not jeopardized.
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