Article 214 of the Costitution of India with Case law
📘 Article 214 of the Constitution of India – High Courts for States
🔹 Text of Article 214:
"There shall be a High Court for each State."
🧾 Explanation:
Article 214 mandates that every State in India shall have a High Court.
However, one High Court can serve more than one State (as per Article 231).
The High Court is the highest court at the state level, exercising:
Original jurisdiction (in some matters like writs),
Appellate jurisdiction (civil/criminal appeals), and
Supervisory jurisdiction over subordinate courts.
🏛️ Notable Examples of Shared High Courts:
Punjab & Haryana share the Punjab and Haryana High Court at Chandigarh.
Assam, Nagaland, Mizoram, and Arunachal Pradesh share the Gauhati High Court.
Union Territories like Delhi have their own (e.g., Delhi High Court).
⚖️ Relevant Case Laws under or related to Article 214:
🔹 **1. State of Assam v. Ranga Muhammad, AIR 1967 SC 442
– Interpreting the jurisdiction and authority of shared High Courts**
Issue: Whether the Gauhati High Court could continue to serve other northeastern states post their formation.
Held: Under Article 214 read with Article 231, a common High Court is valid, and Article 214 does not require each State to have a separate High Court.
🔹 **2. Union of India v. Sankalchand Himatlal Sheth, (1977) 4 SCC 193
– Transfer of judges and High Court independence**
Though focused on Article 222, the Court emphasized the independence and constitutional status of High Courts established under Article 214.
Recognized that High Courts are essential to federal structure.
🔹 **3. L. Chandra Kumar v. Union of India, (1997) 3 SCC 261
– Importance of High Courts under Article 214 in constitutional structure**
Held: High Courts have a central role in judicial review, especially of legislative and administrative actions.
Article 214 and associated provisions give High Courts constitutional status, and tribunals cannot replace their writ jurisdiction under Article 226.
🔹 **4. T.C. Basappa v. T. Nagappa, AIR 1954 SC 440
– High Court’s powers under Article 226 tied to its establishment under Article 214**
Importance: Demonstrates that the High Court, as constituted under Article 214, is not just a statutory body but a constitutional institution empowered to enforce fundamental rights.
📝 Key Points to Remember:
Article 214 is declaratory, establishing the constitutional status of High Courts.
It does not preclude shared High Courts (Article 231 allows this).
High Courts are the bulwarks of fundamental rights via Article 226.
Their existence is not dependent on parliamentary enactment; they are constitutionally guaranteed.
📊 Summary Table:
| Feature | Article 214 | Article 231 |
|---|---|---|
| Purpose | Declares High Court for every State | Allows High Courts for two or more States |
| Type | Mandatory provision | Enabling provision |
| Structure | One per State (general rule) | Exception — shared High Courts |
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