Article 199 of the Costitution of India with Case law
📘 Article 199 of the Constitution of India – Definition of Money Bills (State Legislature)
🔹 Text of Article 199 (1):
A Bill shall be deemed to be a Money Bill if it contains only provisions dealing with all or any of the following matters:
(a) imposition, abolition, remission, alteration or regulation of any tax by the State;
(b) regulation of borrowing of money by the State;
(c) custody of the Consolidated Fund or the Contingency Fund of the State;
(d) appropriation of money out of the Consolidated Fund of the State;
(e) declaring any expenditure to be charged on the Consolidated Fund of the State;
(f) receipt of money on account of the Consolidated Fund or public account of the State;
(g) any matter incidental to any of the matters specified above.
Clause (2): If any question arises whether a Bill is a Money Bill or not, the decision of the Speaker of the Legislative Assembly shall be final.
Clause (3): Every Money Bill shall bear the certificate of the Speaker of the Legislative Assembly to that effect.
🧾 Explanation:
Article 199 is the state-level equivalent of Article 110, which defines Money Bills in the Parliament.
The Money Bill can only originate in the Legislative Assembly (Vidhan Sabha).
The Legislative Council (Vidhan Parishad), if it exists, cannot reject or amend a Money Bill — it can only make recommendations.
The Speaker’s decision is final and cannot be challenged in a court, as per constitutional tradition (though this has been debated).
⚖️ Key Case Laws on Article 199 (and relevant parallels):
🔹 1. Mohd. Saeed Siddiqui v. State of Uttar Pradesh, (2014) 11 SCC 415
Facts: Challenge to the classification of a bill as a Money Bill in U.P.
Held: Speaker’s certification of a Money Bill is final and cannot be judicially reviewed.
Court followed a strict interpretation of Article 199(3).
🔹 2. Karnataka Legislative Assembly case, Re: (Unreported)
A local challenge was raised regarding whether a particular financial bill was properly certified as a Money Bill.
Though not leading to a reported judgment, it highlighted the discretionary power of the Speaker under Article 199(3).
🔹 3. Rojer Mathew v. South Indian Bank Ltd., (2020) 6 SCC 1
Though about Article 110 (Centre), the SC raised doubts about immunity of the Speaker’s decision under Articles 110/199.
Referred the matter to a larger bench to decide whether Speaker's certification is judicially reviewable in extreme circumstances.
Implied relevance for Article 199 at the state level.
🔹 4. State of Punjab v. Sat Pal Dang, AIR 1969 SC 903
SC ruled that the Legislative Council’s powers regarding a Money Bill are limited to making recommendations only.
Reinforced Article 199(2) and (3) regarding Speaker's power and Council's limited role.
📝 Key Takeaways:
Money Bills in States can only originate in the Legislative Assembly.
The Speaker’s certification is final and usually not challengeable in court, though there are emerging views suggesting limited judicial review.
The Legislative Council (if any) cannot amend or reject a Money Bill — only suggest changes within 14 days.
The Bill must deal only with matters listed in Article 199(1); otherwise, it cannot be treated as a Money Bill.
📊 Summary Table:
| Aspect | Article 199 | Article 110 (Centre) |
|---|---|---|
| Level | State | Union |
| Originates in | Legislative Assembly | Lok Sabha |
| Role of Second House | Recommendations only (Legislative Council) | Rajya Sabha has similar role |
| Final Authority | Speaker of Assembly | Speaker of Lok Sabha |
| Judicial Review | Traditionally barred | Under reconsideration (Rojer Mathew case) |
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