M. Karunanidhi v Union of India
M. Karunanidhi v. Union of India (1979), complete with the critical facts, legal issues, Supreme Court reasoning, and lasting impact on constitutional law:
📌 Case: M. Karunanidhi v. Union of India (20 February 1979)
Citations: 1979 AIR 898; 1979 (3) SCC 431 (Indian Kanoon)
⚖️ Background & Facts
Tamil Nadu enacted the Tamil Nadu Public Men (Criminal Misconduct) Act, 1973, amended in 1974, to investigate misconduct by elected public figures—termed “public men” (excluding government servants). It was repealed in 1977, after receiving Presidential assent both at enactment and repeal (Drishti Judiciary).
Karunanidhi, as Chief Minister, was charged under Sections 161, 468, and 471 of the IPC, and under the Prevention of Corruption Act (1976 investigation, ₹4‑5 lakhs alleged pecuniary gain) (Lady Justice Gazette).
🧩 Legal Questions
Repugnancy under Article 254: Did the State Act conflict irreconcilably with Central statutes (IPC, Prevention of Corruption Act, Criminal Law Amendment Act)? If so, did Article 254(2)'s Presidential assent allow it to prevail locally?
Public servant definition: Could a Chief Minister be considered a “public servant” under Section 21(12)(a) IPC and prosecuted accordingly? (Casemine)
🏛️ Supreme Court's Findings
1. Repugnancy & Article 254 (Federal Harmony)
The Court held: the State Act did not contain provisions irreconcilably inconsistent with Central laws. It created distinct offences and included a “saving clause” permitting Central Acts to apply when State investigation completed (Section 29). Hence, no repugnancy arose (Casemine).
Thus Article 254(2) wasn't activated to repeal Central Acts. The Central statutes continued in force even post‑repeal of the State Act (The Law Brigade Publishers (India)).
2. Pith and Substance Doctrine
The State Act’s core (“pith and substance”) was within Tamil Nadu’s legislative domain, and incidental overlap with Central jurisdiction was permissible. The law was upheld on constitutionality grounds (Drishti Judiciary, Casemine).
3. Status of Chief Minister as Public Servant
The Supreme Court rejected the argument that a CM is not a “public servant” merely because of the constitutional nature of the office. It emphasized that remuneration from government treasury and constitutional appointment by the Governor sufficed to classify the CM as subordinated to the State—thus meeting Section 21(12)(a) definition (theforecastfront.com).
A key obiter: the Governor, as appointing authority, is also the dismissing authority, entailing a master‑servant relationship recognized by law (theforecastfront.com).
đź“š Significance & Legacy
Clarified Article 254 jurisprudence: reaffirmed that State laws under the Concurrent List can coexist with Central ones unless they irreconcilably clash—and that repeal does not revive central statutes if they were never superseded (LawBhoomi).
Expanded the definition of public servant: including constitutional functionaries like Chief Ministers under anti-corruption statutes (Indian Kanoon, Casemine).
Guided legislative drafting: highlighted importance of saving clauses and careful design to avoid repugnancy, promoting federal coordination.
🧾 Summary Table
| Feature | Karunanidhi v. Union of India (1979) |
|---|---|
| Key Issue | Conflict between State Act and Central Acts; Sameness of “public servant” status for CM |
| Article Invoked | Article 254(1) & (2) |
| Court’s Decision | State Act not repugnant; CM is a public servant |
| Doctrine Applied | Pith & Substance; Saving clause; master‑servant principle |
| Impact | Federal harmony; broader anti‑corruption accountability; constitutional person satisfaction |
âś… Conclusion
The case of M. Karunanidhi v. Union of India (1979) remains a landmark doctrine‑setting judgment. It defines the boundaries between State and Central laws under the Concurrent List, affirms the reach of anti-corruption legislation to constitutional office holders, and exemplifies how sound constitutional interpretation can preserve legislative harmony while safeguarding accountability.
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