Introduction

Case Citation: Harbhajan Singh v. State of Haryana (2022 INSC 987)
Court: Supreme Court of India
Date: September 20, 2022

This landmark case challenges the constitutionality of the Haryana Sikh Gurdwara (Management) Act, 2014. The petitioner, Harbhajan Singh, an elected representative of the Shiromani Gurdwara Prabandhak Committee (SGPC) from Kurukshetra, contends that the Act infringes upon fundamental rights and usurps legislative powers reserved for the Parliament under the Seventh Schedule of the Constitution of India.

The core issue revolves around whether the State of Haryana possesses the legislative competence to enact a law regulating the management of Sikh Gurdwaras, which were traditionally governed by the SGPC under the Sikh Gurdwaras Act, 1925.

Summary of the Judgment

The Supreme Court of India dismissed the writ petitions challenging the Haryana Act, holding that the State Legislature had the authority to enact the law under Entry 32 of List II of the Seventh Schedule. The Court found that the transitional provisions under the Punjab Reorganisation Act, 1966, and the Inter-State Corporation Act, 1957, did not preclude the State from legislating on the management of Gurdwaras within its jurisdiction. Furthermore, the Court observed that the Haryana Act did not infringe upon the fundamental rights guaranteed under Articles 25 and 26 of the Constitution, as it allowed Sikhs in Haryana to manage their religious affairs autonomously.

Analysis

Precedents Cited

The judgment extensively references several key precedents that influenced its decision:

• Sehajdhari Sikh Federation v. Union of India: This case examined the limits of the Central Government's power under Section 72 of the Punjab Reorganisation Act, 1966, emphasizing that such powers were transitional and limited to ensuring the smooth functioning of inter-state bodies post-state reorganisation.
• Kashmir Singh v. Union Of India: Affirmed that inter-state bodies like the SGPC could receive directions from the Central Government under transitional provisions but underscored that such powers were not permanent and did not override state legislative competence.
• Himachal Pradesh University, Shimla: Clarified that state legislatures retain the authority to legislate on subjects within their jurisdiction even if institutions like universities straddle multiple states.
• Union Of India v. Rajendra N. Shah: Highlighted that cooperative societies involved multiple states fall under the Union List, distinguishing them from intra-state bodies managed under the State List.

Legal Reasoning

The Court's legal reasoning centered on the interpretation of the Seventh Schedule of the Constitution, specifically Entry 32 of List II and Entry 44 of List I:

• Entry 32, List II: Pertains to the incorporation, regulation, and winding up of corporations other than those specified in List I, including religious and other societies and associations. The Court concluded that the Haryana Act falls squarely within this entry, empowering the State to legislate on the management of Gurdwaras.
• Entry 44, List I: Deals with corporations whose objects are not confined to one State, thus requiring Union oversight. However, the Court determined that the SGPC's transformation into an inter-state body under transitional provisions did not strip the State of its legislative powers over matters within its borders.

Additionally, the Court emphasized that transitional laws like the Punjab Reorganisation Act and the Inter-State Corporation Act were meant to facilitate the reorganization process and did not grant perpetual legislative authority to the Central Government over state matters.

Impact

This judgment reinforces the autonomy of State Legislatures in managing religious institutions within their jurisdictions. It clarifies that:

• States retain the power to legislate on the management of religious properties and institutions under Entry 32 of List II, despite existing inter-state bodies like the SGPC.
• Transitional provisions do not permanently encroach upon state legislative powers, ensuring that states can adapt and legislate independently as their administrative needs evolve.
• The decision upholds the balance of power between the Union and State governments, preventing undue centralization of authority over religious affairs.

Future cases involving the management of religious or charitable institutions will likely reference this judgment to determine the appropriate legislative domain, especially in contexts where state and inter-state bodies intersect.

Complex Concepts Simplified

Conclusion

The Supreme Court's judgment in Harbhajan Singh v. State of Haryana underscores the enduring principle of federalism enshrined in the Indian Constitution. By affirming the State of Haryana's legislative competence to enact the Sikh Gurdwara (Management) Act, 2014, the Court reasserted the autonomy of state legislatures in managing religious institutions within their territories. The decision carefully delineates the boundaries between state and central powers, ensuring that transitional provisions do not erode the foundational legislative authority of the states.

This judgment not only resolves the immediate legal challenge but also sets a clear precedent for the legislative management of religious and charitable institutions across India. It affirms that while central oversight is necessary for inter-state entities, states retain significant autonomy to govern intra-state matters, preserving the constitutional balance of power.