Article 131

Article 131 of the Constitution of India grants the Supreme Court original and exclusive jurisdiction in specific categories of disputes involving the Union of India and the States. This Article ensures that when constitutional or legal disagreements arise between different tiers of government, a single and authoritative body—the Supreme Court—acts as the ultimate arbiter. It plays a crucial role in maintaining the federal balance of the Indian Union and in upholding the rule of law among its constituent units.

Nature and Scope of Original Jurisdiction

The term “original jurisdiction” refers to the authority of a court to hear a case for the first time, as opposed to appellate or review jurisdiction. Under Article 131, such jurisdiction is both original and exclusive, meaning that only the Supreme Court can entertain these disputes, and no other court—whether High Court or subordinate—has competence to do so.
Article 131 states:

“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;(b) between the Government of India and any State or States on one side and one or more other States on the other;(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.”

This provision ensures that disputes of constitutional or legal significance between the Union and the States are adjudicated by the apex judicial authority, thereby ensuring uniformity and impartiality in interpretation.

Types of Disputes Covered

Article 131 encompasses three broad categories of disputes:

• Disputes between the Union Government and one or more States: For example, disagreements over administrative authority or financial obligations.
• Disputes between the Union and certain States on one side and other States on the opposite side: Such disputes may arise from intergovernmental arrangements or constitutional powers.
• Disputes between two or more States: Typically involving boundaries, water-sharing rights, or jurisdictional conflicts, provided the matter pertains to a legal right and not merely a political grievance.

Through these provisions, Article 131 serves as a constitutional mechanism for the peaceful resolution of conflicts within India’s federal framework.

Exclusions from Jurisdiction

Article 131 explicitly excludes certain matters from the Supreme Court’s original jurisdiction:

• Disputes arising from treaties, agreements, covenants, or similar instruments made before the commencement of the Constitution.
• Issues that are expressly excluded from its jurisdiction by other provisions of the Constitution.

This ensures that the Court’s jurisdiction remains confined to post-constitutional legal disputes and does not interfere with matters of historical or political character that may have been settled prior to 1950.

Judicial Interpretation and Landmark Judgments

The Supreme Court has, through various judgments, clarified and shaped the contours of Article 131. Some of the most significant cases include:

• State of West Bengal v. Union of India (1963): The Court held that Article 131 encompasses only legal disputes, not political ones. It ruled that the State cannot challenge the constitutional validity of a parliamentary law enacted under the Constitution in a suit under Article 131.
• State of Rajasthan v. Union of India (1977): The Court ruled that political questions, such as the validity of the proclamation under Article 356 (President’s Rule), do not fall within the purview of Article 131.
• State of Karnataka v. Union of India (1977): This judgment reaffirmed that disputes under Article 131 must involve a justiciable issue concerning legal rights and not mere differences in political or administrative opinion.
• Union of India v. State of Gujarat (2000): The Court clarified that the jurisdiction extends to inter-governmental disputes involving interpretation of constitutional provisions or statutory obligations.

Through these rulings, the Supreme Court has consistently maintained that its original jurisdiction is narrowly tailored to legal disputes, ensuring that it does not become a platform for political contention.

Federal Significance of Article 131

India’s federal structure, though tilted towards a strong Centre, requires a neutral judicial forum for resolving conflicts between the Union and the States. Article 131 serves precisely this purpose. It upholds the principles of cooperative federalism by ensuring that disputes are resolved legally and constitutionally, rather than politically or administratively.
By vesting such jurisdiction in the Supreme Court, the Constitution ensures:

• Uniform interpretation of the constitutional division of powers.
• Avoidance of jurisdictional conflicts between High Courts.
• Preservation of federal harmony through judicial adjudication rather than executive interference.

Related Constitutional Provisions

Several other Articles complement Article 131 in defining the Supreme Court’s role and powers:

• Article 124: Establishes the Supreme Court and outlines its composition and powers.
• Article 129: Declares it a court of record with power to punish for contempt.
• Article 132–136: Deal with appellate jurisdiction, including special leave to appeal.
• Article 32: Provides citizens the right to approach the Supreme Court directly for enforcement of fundamental rights.

While these provisions collectively expand the Supreme Court’s jurisdictional reach, Article 131 remains distinctive for its exclusive and original nature.

Practical Applications and Limitations

In practical terms, Article 131 serves as a legal safeguard for States to assert their rights against perceived central overreach. For example, disputes over taxation powers, inter-state water distribution, or administrative control can be raised under this provision.
However, the Article’s scope is limited:

• It does not extend to disputes of a political or administrative nature.
• It excludes matters arising out of pre-constitutional agreements.
• It requires that the dispute must involve a question of legal right, not a mere difference in opinion or policy.

Furthermore, States cannot challenge the constitutionality of a Central law under Article 131; such challenges must be brought through other constitutional remedies.

Contemporary Relevance

In recent years, several States have invoked Article 131 to challenge central policies perceived as infringing upon state powers—for instance, disputes over the Citizenship (Amendment) Act, 2019, and farm laws. These cases illustrate the Article’s continued relevance in defining the boundaries of legislative and executive authority within India’s constitutional framework.

Constitutional Significance

Article 131 represents a cornerstone of India’s federal equilibrium. It provides a judicial mechanism that prevents intergovernmental disputes from escalating into political conflicts. By assigning this responsibility to the Supreme Court, the Constitution ensures that issues of national importance are resolved with finality, impartiality, and constitutional fidelity.