State of West Bengal v Union of India (1963)

Constitutional Law II · Federalism

Facts.

Parliament passed the Coal Bearing Areas (Acquisition and Development) Act, 1957, empowering the Centre to acquire coal-bearing land, including land owned by the State of West Bengal. The State argued that as a “sovereign” it was immune and Parliament had no power to acquire State property.

Issue.

Are the Indian States sovereign, and is the Constitution a compact between sovereign units?

Held.

No. Indian States were never independent sovereigns; the Constitution created a Union with a strong Centre. Parliament could acquire State land. India is federal in form but with a pronounced unitary bias — quasi-federal.

Why it matters.

It is the foundational statement that Indian federalism does not rest on State sovereignty — the master idea of Unit I.

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