Article 131 of Indian Constitution: Jurisdiction of Supreme Court Explained

India’s federal structure, as designed by the framers of the Constitution, anticipates both cooperation and occasional conflict between the Union and its States. Disputes may arise—some trivial, others fundamental—which require a neutral, authoritative arbitrator. Article 131 of the Indian Constitution grants the Supreme Court original and exclusive jurisdiction to resolve such disputes, reflecting both the foresight and complexity of India’s constitutional framework. The spirit behind Article 131 is rooted in the balance of power and the safeguarding of constitutional order, underlining its pivotal role in India’s federal jurisprudence.

Understanding Article 131: Text and Scope

Article 131 of the Constitution reads:

“Subject to the provisions of this Constitution, the Supreme Court shall, to the exclusion of any other court, have original jurisdiction in any dispute— (a) between the Government of India and one or more States; or (b) between the Government of India and any State or States on one side and one or more other States on the other; or (c) between two or more States, if and in so far as the dispute involves any question (whether of law or fact) on which the existence or extent of a legal right depends.”

What stands out is the Supreme Court’s unique responsibility—it acts not as an appellate authority but as a trial court for these federal disputes. This structure secures judicial neutrality, preventing state courts from appearing partial in conflicts involving their own governments.

The Nature of Jurisdiction: What Does “Original and Exclusive” Mean?

The jurisdiction under Article 131 is both original (cases are directly filed in the Supreme Court, not via appeals) and exclusive (no other court can hear such cases). It is limited strictly to legal rights—political disagreements or policy disputes are typically outside its reach.

The provision covers disputes:
– Between the Centre and one or more States,
– Among States themselves,
– Between the Centre (with or without States on the same side) and one or more States on the other.

Notably, cases arising from private parties, individuals, or companies do not fall under Article 131.

Key Tests and Judicial Interpretation

Over decades, the Supreme Court has clarified—through landmark judgments—the contours of Article 131 jurisdiction.

Legal Right Versus Political Question

Disputes under Article 131 must involve an enforceable legal right, not mere political statements or policy differences. For instance, in State of Rajasthan vs. Union of India (1977), the Supreme Court refused to intervene in matters it considered political rather than legal.

“Article 131 is neither a charter for all Centre-State squabbles, nor a remedy for every inter-state misunderstanding. The Court’s door opens only when legal rights, not political motivations, are at stake.”
— (Justice P.N. Bhagwati, paraphrased from State of Rajasthan v. Union of India)

Nature of Parties

In State of Haryana v. State of Punjab (2002), the apex court held that the parties before it should be the units mentioned in Article 131 alone. Inclusion of private parties can disqualify the suit from being entertained under this provision. However, the State may represent public interests, such as river water disputes, if it does so in its capacity as a sovereign entity.

Exclusion of Contractual and Statutory Claims

Not all disputes involving States and the Union are justiciable under Article 131. For example, contractual disputes, such as those concerning supply agreements, or cases where statutory tribunals are already specified for resolution, will generally not qualify.

Article 131 in Action: Case Studies and Real-World Scenarios

Certain high-profile disputes have underscored the centrality of Article 131.

Water Disputes

The Supreme Court has repeatedly addressed disagreements between States over river water sharing, as seen in the continuing Cauvery Water Dispute involving Tamil Nadu and Karnataka. While specific tribunals are often constituted for such cases, when states frame their disputes purely as constitutional or legal rights (and tribunal recourse is unavailable), Article 131 becomes the appropriate mechanism.

Taxation and Economic Policies

In 2019, several State governments challenged the constitutional validity of the Centre’s Goods and Services Tax (GST) on grounds of federal encroachment under Article 131. While such suits are rare and often dismissed if a separate remedy exists, the readiness of States to invoke Article 131 highlights its ongoing relevance.

The Citizenship Amendment Act Challenge

Kerala’s 2020 suit under Article 131 questioned the constitutional validity of the Citizenship Amendment Act (CAA)—an unprecedented move that tested the boundaries of the provision. The maintainability of this suit remains under judicial consideration, with debate over whether a State can challenge central legislation via Article 131 on behalf of its citizens.

Process: How a Suit Under Article 131 Proceeds

When a suit is filed invoking Article 131, it bypasses all subordinate courts and comes directly before the Supreme Court. The process involves:

1. Filing of plaint by the affected State or Union.
2. Scrutiny by the Supreme Court to establish jurisdiction (i.e., whether it falls within Article 131).
3. Pleadings, written arguments, and hearings, usually before a bench of at least five judges when constitutional interpretation is involved.
4. Final decision—binding on all parties, given the Supreme Court’s constitutional authority.

This drawn-out, high-stakes litigation underscores the seriousness with which Article 131 disputes are treated.

Critical Perspective: Strengths, Limitations, and Evolving Relevance

Strengths

• Neutral Adjudication: Ensures perceived impartiality in Centre-State disputes.
• Constitutional Safeguard: Acts as a check on executive overreach and preserves federal balance.
• Direct Route: Eliminates prolonged litigation in lower courts.

Limitations

• Narrow Scope: Only certain “legal rights” qualify—many pressing issues remain outside its ambit.
• Procedural Rigidity: The requirement for exclusive party standing can restrict access.
• Slow Process: Cases under Article 131 can drag on, particularly with constitutional complexity.

Evolving Relevance

Recently, a more assertive federal structure and periodic legislative tensions have brought Article 131 into greater focus. As States seek greater autonomy—the Centre’s policies on taxation, language, and citizenship, among others, have increasingly been challenged under this article. However, the Supreme Court remains careful to preserve the constitutional intent, filtering out cases that do not strictly invoke its original jurisdiction.

Conclusion: Article 131 as the Guardian of Federal Equilibrium

Article 131 embodies a pivotal commitment to federalism—providing a forum for States and the Union to resolve fundamental constitutional disputes. While not a panacea for every Centre-State disagreement, its presence in the supreme law of the land ensures legal recourse exists for the most critical tensions in India’s complex polity. As India’s democracy evolves, so too will the interpretation and invocation of this vital provision, reinforcing the delicate balance between unity and regional autonomy.

FAQs

What types of disputes does Article 131 of the Indian Constitution cover?

Article 131 covers disputes strictly between the Government of India and one or more States, or among States themselves, involving questions of legal rights—not political or personal grievances.

Can individuals or private parties file a case under Article 131?

No, Article 131 jurisdiction is exclusive to the Union and State governments. Individuals or private entities cannot directly approach the Supreme Court under this article.

How is Article 131 different from appellate jurisdiction?

Unlike appellate jurisdiction, where the Supreme Court reviews decisions from lower courts, Article 131 gives the Supreme Court the power to hear certain Centre-State and inter-State disputes as a court of first instance.

Are contractual or financial disputes between the Centre and States covered under Article 131?

Generally, contractual or purely financial disputes are not entertained under Article 131. Only cases that involve enforcement or interpretation of constitutional or legal rights between States or the Centre qualify.

Can a State use Article 131 to challenge central laws?

A State may attempt to invoke Article 131 to challenge central laws, as seen in recent cases, but the Supreme Court carefully examines whether the dispute pertains to a legal right and whether such a challenge falls within the article’s scope.

Why is Article 131 important in India’s constitutional structure?

Article 131 serves as a key mechanism for resolving fundamental legal disputes in a neutral setting, helping maintain balance and trust between the Centre and the States—a cornerstone of Indian federalism.