"Though the country and the people may be divided into different states for convenience of administration, the country is one integral whole, its people a single people living under a single imperium derived from a single source." - Dr. B.R.Ambedkar (Chairman, Drafting Committee of the Constitution of India)

The Indian constitution delineates the separation of legislative, executive, and financial powers between the central and state governments, imbuing it with a civic character, while the judiciary is structured in a categorized manner. Center-state relations are divided into three main aspects: Legislative Relations, Administrative Relations, and Financial Relations. Articles 245 to 255 elaborate on legislative relations, while Articles 256 to 263 address administrative relations, and Articles 268 to 293 explain financial relations between the center and state governments. Various committees and commissions have been established to propose constitutional amendments aimed at strengthening center-state relations by decentralizing power to state governments.

The 73rd and 74th constitutional amendments decentralized power to states through local governance. This paper seeks to examine the issues and challenges of center-state relations in India through descriptive research methods, utilizing secondary sources such as books, journals, government reports, and reports from various commissions and committee.

Introduction
The Indian constitution divides legislative, executive, and financial powers between the central and state governments, giving it a civic character, while the judiciary is structured categorically. Center-state relations are categorized into legislative, administrative, and financial aspects, as delineated in Articles 245 to 255, 256 to 263, and 268 to 293 respectively. This division is essential for assessing the federal structure of governance in the Constitution.

While a centralized structure concentrates power regionally between the center and states, leading to limited governments. India, as the seventh largest country globally, has faced demands for greater autonomy from its modern states, which originated during British rule. Despite the unitary features emphasized in the Indian constitution, India operates as a union of states rather than a federation, resulting in a quasi-federal structure.

This setup has created tensions between the powerful center and relatively weaker states. With the emergence of alliance politics, states have gained prominence, with provincial parties playing a significant role in national decision-making. Today, states not only act as force groups but also play pivotal roles in trade, business, and increasingly in foreign policy matters.

The Constitution of India, while designed as federal in form, exhibits a more unitary character, with a significant concentration of powers in the hands of the Union Government. This imbalance in power distribution between the center and states has been a longstanding issue, impacting the effective functioning of democracy and the aspirations of the people governed by state governments.[1]

Over time, various socio-economic and political changes, especially since 1991 with the shift towards a market-oriented economic strategy, have posed new challenges to the federal structure. Issue regarding Centre-State relations, encompassing powers, functions, and responsibilities, have been a recurring concern, highlighted in forums like the Srinagar Conclave and subsequent Chief Ministers' conferences.

These issues span administrative, legislative, and financial domains. Administrative concerns include the misuse of Article 356, deployment of Central forces without state consent, and the role of Governors. Legislative matters revolve around the encroachment of the Center into state-list subjects and delays in obtaining assents for state bills. Financial issues include the centralization of powers in resource mobilization, allocation, and economic decision-making.

Efforts to address these issues, such as the establishment of the Sarkaria Commission in 1983, have yielded limited results. Despite recommendations, particularly in the financial sphere, implementation has been lacking. The formation of the Inter-State Council in 1990 aimed to tackle these challenges, but unresolved issues persist, compounded by new problems arising in the post-liberalization era. The UPA Government initiated another Commission on Centre-State Relations in April 2007, chaired by former Chief Justice MM Punchhi.

However, the terms of reference did not fully align with states' demands for greater financial autonomy, focusing instead on issues like law and order and the deployment of Central forces, encroaching on states' jurisdiction. This highlights the need to revisit and address unresolved issues while identifying and resolving new challenges in Centre-State relations.

A key feature of a federal constitution is the allocation of powers between the central government and the state governments. The Indian Constitution, tailored to suit the country's specific requirements, adopts a unique form of federalism. Drawing inspiration from the Government of India Act, 1935, the framers of the Constitution opted for a model where the Union Parliament holds greater authority over legislative matters compared to the State Legislatures/Assemblies.

The Indian Constitution, founded on federal principles, establishes a dual system for the distribution of legislative powers based on territory and subject matter. These provisions are outlined in Articles 245-254. Article 245 addresses the distribution of legislative authority between the Union and the States concerning territory. Article 246 delineates the three Lists contained in Schedule VII of the Constitution: the Union List, the State List, and the Concurrent List.

In the event of a conflict between a central law and a state law regarding a subject in the Concurrent List, the central law takes precedence. Additionally, under Article 248 and Entry 97 of the Union List, residual powers in India are vested in the central government. This demonstrates the inclination of the Constitution's framers towards a centralized form of governance.

While under normal circumstances, the distribution of powers between the Centre and the States must be strictly upheld, there are certain exceptional situations where the Union Parliament's authority extends to subjects allocated to the State List. This could occur, for instance, during a Proclamation of Emergency or with the consent of the State in the event of a breakdown of constitutional machinery. Despite granting more powers to the Union Parliament compared to the States, the framers ensured that the states are not subordinate to the Centre. They maintain sufficient autonomy to function as independent centers of authority during normal times.

Legislative powers are constrained by the distribution of powers outlined in the three lists of Schedule VII of the Constitution, fundamental rights, and other constitutional provisions (Articles 245-255). Neither the Union Parliament nor a State Legislature can be considered sovereign in a legalistic sense, as each is bound by the provisions of the Constitution, the scheme of power distribution, and fundamental rights.

The Constitution of India provides a dual polity with a clear division of powers between the Union and the States, each being supreme within the sphere allotted to it. The Indian Federation is not the result of an agreement between independent units, and the units of Indian federation cannot leave the federation. The Constitution contains elaborated provisions to regulate the various dimensions of the relations between the Centre and the States.

The relations between the Centre and the States are divided as follows:

1. Legislative relations
2. Administrative relations
3. Financial relations

Legislative Relations
Distribution of Legislative Powers
Chapter I of Part XI (Article 245-255) of the Indian Constitution specified two-fold division of Legislative powers between the Union and the States.

1. with respect of territory (Territorial jurisdiction)
2. with respect of subject matter

With respect of territory (Territorial jurisdiction)
Article 245 of the Indian Constitution provides for the extent of laws made by the Parliament and by the State Legislatures. As regards territory, Article 245 (1) provides that subject to the provisions of this constitution, a State Legislature may make laws for the whole or any part of the state to which it belongs. It is not possible for a State Legislature to enlarge its territorial jurisdiction under any circumstances except when the boundaries of the state itself are widened by an act of Parliament.

In terms of territorial jurisdiction, Chapter I of Part XI (Articles 245-255) of the Indian Constitution establishes a dual division of legislative powers between the Union and the States.

Article 245 delineates the extent of legislative authority granted to both the Parliament and the State Legislatures concerning territory. It states that, subject to the provisions of the Constitution, a State Legislature can enact laws for the entirety or any part of the state to which it pertains. However, a State Legislature cannot extend its territorial jurisdiction beyond the boundaries defined for the state, unless those boundaries are altered by an act of Parliament. In contrast, Parliament possesses the authority to legislate for the entire territory of India, encompassing not only the states but also the union territories.

Article 245 also addresses several key doctrines:

1. The Doctrine of Extra-territorial Operation: Parliament holds the power of extra-territorial legislation, which is not available to state legislatures. This enables laws enacted by Parliament to govern individuals and assets not only within the territorial bounds of India but also Indian nationals and assets situated anywhere globally. Parliament's laws are not considered invalid solely because they have extra-territorial effects[2].
    
2. The Doctrine of Territorial Nexus: Parliament is empowered to legislate for territories within India, even if the laws may have implications beyond India's borders. However, it is not authorized to legislate for territories outside India. Article 245 establishes the territorial scope of legislative authority for both Parliament and the State Legislatures, while also outlining the specific doctrines guiding the exercise of legislative powers by Parliament. The determination of whether the connection is real or unreal is a matter of fact to be decided by the Courts[3].

In the case of State of Bombay v. RMDC[4], the respondent, although not residing in Bombay, organized competitions with prize money through a newspaper published in Bangalore but widely circulated in Bombay. All essential activities related to the competition, such as form submissions and entry fees, took place in Bombay. The State government sought to levy taxes on the respondent for conducting business within the state.The Supreme Court deliberated on whether the respondent, despite being outside the state of Bombay, could be lawfully taxed under the Act.

In Wallance v. ITC, Bombay[5], a company that was registered in England was a partner in a firm in India. The Indian Income-tax Authorities sought to tax the entire income made by the company. The privy council applied the Doctrine of Territorial Nexus and held the levy tax valid.

With respect of subject matter
With regard to subject matter, a federal system entails the distribution of powers between the central and state governments. The specific nature of this distribution varies based on the local and political context of each country. In the United States, for instance, the individual states preferred not to be entirely subordinate to the central government.

Therefore, they opted to delegate subjects of common interest to the central government while retaining authority over others. On the other hand, Canada, having observed the challenges faced by the United States, particularly the Civil War of 1891, chose to establish a robust central authority. The framers of the Indian Constitution followed a similar path, drawing inspiration from the Canadian model, which emphasized a strong central government. However, they introduced an additional list known as the Concurrent List.

Regarding the subjects for legislation, the Constitution borrows from the Government of India Act, 1935, and divides legislative powers between the Union and the States into three lists: the Union List, the State List, and the Concurrent List. Article 246 outlines the subject matter for laws enacted by both Parliament and the State Legislatures, providing a detailed framework for their respective legislative domains. The lists are as follow:

• The Union List:
  Notwithstanding anything in clauses (2) and (3), Parliament has exclusive power to make laws with respect to any of the matters enumerated in List I in the Seventh Schedule referred to as the "Union List." This list comprises of 97 subjects of National or All-India importance, for example, defense, foreign affairs, currency, railway, etc., on which the Parliament alone (exclusive area) can make law^[6].
   
• The State List:
  Subject to clauses (1) and (2), the Legislature of any State has exclusive power to make laws for such State or any part thereof with respect to any of the matters enumerated in List II in the Seventh Schedule referred to as the "State List"^[7]. This list comprises of 66 subjects of local interest, for example, public order & police, public health, agriculture, forest, etc., on which the State Legislatures can make law except under Article 249, 253, when the Parliament can make law on these subjects.
   
• The Concurrent List:
  The Concurrent list is a unique feature of the Indian Constitution as it is not found in any other federal constitution like America & Australia. It makes our federalism flexible. Notwithstanding anything in clauses (3), Parliament and, subject to clause (1), the Legislature of any State also, have power to make laws with respect to any of the matters enumerated in List III in the Seventh Schedule referred to as the "Concurrent List"^[8]. This list comprises of 47 subjects, for example, criminal law and procedure, civil law, marriage, contracts, torts, etc., on which both the Parliament and the State Legislatures can make law.

Position in case of inconsistency between laws made by Parliament and laws made by State Legislatures on the subject of the Concurrent List (Article 254):

But in case of any clash between the Centre law and the State law, the overriding power rests with the Centre. If any provision of a law made by State Legislature is repugnant to any provision of a law made by Parliament, then the law made by Parliament shall prevail and the State law shall, to the extent of repugnancy, be void. Where a law made by a State Legislature with respect to any matter enumerated in the Concurrent list contains any provision repugnant to the provisions of an earlier law made by Parliament or an existing law with respect to that matter, then, the law so made by the Legislature of such State shall, if it has been reserved for the consideration of the President and has received his assent, prevail in that State"

Residuary powers (Article 248)
It is quite interesting to note that the residuary powers are vested in the union, while in the United States of America and Australia, these powers are given to the states. Article 248 says that, Parliament has exclusive power to make any law with respect to any matter not enumerated in any one of the three lists. This reflects the leanings of the Constitution-makers towards a strong centre. Another notable thing regarding to residuary powers is that 'the final determination as to whether a particular matter falls under the residuary power or not is that of the courts.

Doctrine of Pith and Substance
The doctrine of Pith and Substance is one of the principles of interpretation of lists provided in the Seventh Schedule of the Constitution of India. This doctrine is the original native of Canada and has been propounded for the first time in Cushing v. Duper case. This has been borrowed from the Canadian model. Pith means true nature or essence of something" and Substance means "most important part of something" The doctrine of Pith & Substance says that where the question arises of determining whether a law relates to a particular subject, the Court looks to the substance of the matter[9].

In Prafful Kumar v. Bank of Commerce[10] case concerned the constitutionality of the Bengal Moneylenders Act, 1940, which was adopted by state legislatures. It was contested on the grounds that the Act only applied to promissory notes. As the subject matter of promissory note comes under the Union List, it was argued that the state had no power to create laws concerning a union matter. The SC here held that the encroachment was incidental hence making the act valid.

Doctrine of Harmonious Construction
According to this doctrine, a provision of the statute should not be interpreted or construed in isolation but as a whole, so as to remove any inconsistency or repugnancy. The courts must avoid a clash on contradicting provisions and they must construe the opposing provisions so as to harmonize them. When the court is unable to reconcile the differences between opposing provisions, the courts must interpret them in such a manner that both the opposing provisions are given effect as much as possible.

The objective of harmonious construction: The objective of harmonious construction is to avoid any confrontation between two enacting provisions of a statute and to construe the provisions in such a way so that the harmonize[11].

The basis of this rule is that the Legislature never envisages to provide two conflicting provisions in a statute, for the reason that it amounts to self-contradiction. The real legislative intent, that we try to discover in the process of interpretation cannot be to provide for something in one provision and deny the same in subsequent one. Hence, even if an inconsistency is found, the same should be considered to be unintentional and as such, is required to be cured by way of harmonious construction[12].

Doctrine of Repugnancy
The doctrine of repugnancy, in accordance with Article 254, states that if any part of State law is repugnant or conflicting to any part of a Central law which the Parliament is competent to enact, or to any part of a law of the matter of List III, then the Central law made by the Parliament shall prevail and the law made by the State legislature shall become void, to the extent of its repugnancy[13].

Administrative Relations:
The Constitution of India outlines administrative relations between the Centre and the States through Articles 256 to 263. In 2007, the Punchhi Commission was established by the Government of India to examine these relations.

Article 246 specifies the legislative subjects for both Parliament and State Legislatures, with Schedule VII categorizing them into Union, State, and Concurrent Lists. Generally, the Central Government has administrative control over subjects falling under Parliament's jurisdiction, while State Governments have authority over matters listed in the State List.

The obligation of States and the Union
Article 256 of the Indian Constitution can be divided into two main aspects.

Firstly, it mandates that State executive powers must be exercised in conformity with laws enacted by the Parliament or other applicable laws. Secondly, it empowers the Union to issue directions to the States deemed necessary by the Central Government.

This provision suggests that if States adhere to the first aspect, the need for the second may be obviated. However, the existence of the second aspect implies that States may sometimes fail to comply with the first. The Constitution includes this provision under the assumption that States may, at times, either deliberately defy or neglect their duties.

Article 256 succeeds Section 122 of the Government of India Act, 1935. Although it doesn't specify consequences for non-compliance, Article 365 of the Constitution introduces a significant sanction. If a State fails to follow Union directions, the President can declare a situation where the State's government cannot function as per the Constitution, leading to the imposition of a state emergency. The underlying principle is the proper implementation of central laws across all States.

Precedents
Control of the Union over States in certain cases
Article 257 of the Constitution of India, 1950 deals with this subject:

• Article 257(1) stipulates that the exercise of State executive powers should not impede the Centre's executive powers, and similar to Article 256, it allows the Centre to issue directions to State Governments when necessary.
• Article 257(2) expands the Union's power to issue directions to States to include matters concerning the construction and maintenance of nationally or militarily important means of communication, even though communication is a State subject under Schedule VII.

The proviso clarifies that this provision doesn't limit Parliament's power to:

1. Declare certain highways or waterways as national ones,
2. To construct and maintain communication means for naval, military, and air force purposes.

Article 257(3) extends the Union's power to issue directions to States for protecting railways within a State.

Article 257(4) states that if States incur additional costs due to complying with directions under clauses (2) or (3), the Government of India will reimburse them as agreed upon. If no agreement is reached, the extra costs will be determined by an arbitrator appointed by the Chief Justice of India.

Power of the Union to confer powers, etc. on States
Article 258 of the Indian Constitution delineates the provisions regarding the Union's authority to confer powers on States in specific cases.

Article 258(1) empowers the President, with the Governor of the State's permission, to delegate, conditionally or unconditionally, to the State Government or its officers, functions related to any matter falling within the Union's executive powers.

Article 258(2) allows Parliament-made laws applicable in a State to confer powers, impose duties, or authorize such actions upon the State or its officers, even if the State Legislature lacks the authority to legislate on the matter.

Article 258(3) mandates that the Government of India reimburses States for additional administrative costs incurred due to exercising the conferred powers and imposed duties. In case of disagreement, an arbitrator appointed by the Chief Justice of India determines the amount.

Article 258-A of the Indian Constitution addresses the authority of States to delegate functions to the Union. Beginning with a non-obstante clause, Article 258-A stipulates that with the consent of the Union Government, the Governor of a State may entrust, conditionally or unconditionally, to the State government or its officers, functions pertaining to any matter falling within the State's executive powers.

This provision was introduced into the Constitution by the Constitution (Seventh Amendment) Act, 1956.

• Public acts, records and judicial proceedings:
• Article 261 of the Constitution of India deals with public acts, records and judicial proceedings.
• Article 261(1) provides that full faith and credit must be given to all the public acts, records and judicial proceedings of the Union and every State, throughout the territory of India.
• Article 261(2) provides that the manner in which and conditions under which the aforementioned acts, records and proceedings are to be proved along with the effect thereof, shall be provided by such law as made by the Parliament.

• Adjudication of disputes relating to inter-state water disputes:
• Article 262 of the Indian Constitution addresses the adjudication of disputes concerning inter-State rivers or river valleys.
• Article 262(1) grants Parliament the authority to enact laws for the adjudication of disputes or complaints related to the utilization, distribution, or control of waters in any inter-state river or river valley.
• Article 262(2) includes a non-obstante clause, allowing Parliament to legislate that neither the Supreme Court nor any other court shall have jurisdiction over such disputes mentioned in clause (1).

States possess legislative power over water issues under Entry 17 of the State List, while the Union can legislate on the same under Entry 56 of the Union List. In compliance with Article 262, Parliament enacted the Inter-State Water Disputes Act, 1956. When disputes cannot be resolved through negotiations, the Central Government establishes Water Disputes Tribunals for adjudication. Presently, there are five active tribunals: Ravi and Beas Water Tribunal, Krishna Water Disputes Tribunal - II, Vasundhara Water Disputes Tribunal, Mahadayi Water Disputes Tribunal, and Mahanadi Water Disputes Tribunal.

Various legal doctrines, such as Riparian Rights, Prior Appropriation, Territorial Sovereignty, Community of Interest, and Equitable Apportionment, pertain to inter-state water issues.

The Supreme Court's ruling in the State of Kerala vs. State of Tamil Nadu (2018) case brought resolution to the long-standing Kaveri Water Dispute. Article 261(3) states that final judgments or orders which are delivered or passed by the civil courts located in any part of the Indian territory are capable of execution anywhere within that territory, according to the law.

Provisions with respect to an Inter-State Council
Article 263 of the Indian Constitution empowers the President to establish an inter-State Council if it serves the public interest. The President defines the Council's duties, organization, and procedures through an order. The Council can be tasked with:

1. Resolving disputes between States.
2. Discussing and investigating subjects of common interest to some or all States, or between the Union and one or more States.
3. Making recommendations on various subjects, especially for better coordination of policies and actions. The Inter-State Council, established in 1990 based on the recommendations of the Sarkaria Commission in 1988, serves as a permanent national forum for consultation. Recently, in 2019, the Council was reconstituted with the Prime Minister serving as its chairperson.

FINANCIAL RELATIONS
The provisions regarding financial relations between the Union and the States are rooted in the Government of India Act, 1935. Taxation areas are clearly delineated between the two entities, with States having limited taxation powers and relying heavily on the Union for financial resources, chiefly through grants-in-aid.

The seventh schedule of the Constitution designates specific entries for taxation by the Union and the States. The Union can levy taxes on items listed in the Union List, while States have taxation authority over items listed in the State List. The Parliament holds residual taxation powers.

Tax Revenues Are Classified Into Four Categories:

1. Taxes levied by the Union but collected and entirely appropriated by the States (Article 270), such as stamp duties and excise duties on medicinal and toilet preparations.
2. Taxes levied and collected by the Union but wholly assigned to the States (Article 269), including duties on property succession, estate duty, terminal taxes on goods and passengers, and taxes on railway fares and freights.
3. Taxes levied and collected by the Union and distributed between the Union and the States (Article 270), such as taxes on income other than agricultural income.
4. Taxes levied and collected by the Union but shared with the States if Parliament so decides. This includes customs and excise duties. In addition to revenue devolution, the Centre provides grants-in-aid to States under Article 275 for promoting the welfare of Scheduled Tribes and raising the administration level in Scheduled Areas. Additionally, grants are allocated to States annually based on the recommendations of the Finance Commission.

Borrowing Powers:
Article 292 of the Constitution empowers the Union government to borrow money, domestically or internationally, against the security of the Consolidated Fund of India, subject to parliamentary limitations. Recently, State governments have also been authorized to borrow money on similar terms from outside India.

Finance Commission:
Article 280 of the Constitution establishes the Finance Commission, constituted by the President every five years. It comprises a chairman and four members.

The Finance Commission is tasked with recommending to the President:

1. the distribution of tax proceeds between the Union and the States, and among the States themselves;
2. principles guiding grants-in-aid from the Consolidated Fund of India; measures to enhance State Consolidated Funds to support local bodies; and
3. any other financial matters referred by the President. Twelve Finance Commissions have been established to date, with the Thirteenth Finance Commission, chaired by C. Rangarajan, being the most recent.

Financial Relations During Emergency:
During a financial emergency declared under Article 360, the Union government gains certain powers, including:

1. Issuing directives to States regarding financial propriety.
2. Instructing States to reduce salaries and allowances of public servants, including judges.
3. Reserving all money bills and financial bills passed by State Legislatures for the President's consideration.

Conclusion
Effective collaboration between the Central Government and State Governments is a fundamental aspect of Indian federalism, aimed at ensuring the safety and welfare of Indian citizens. This collaboration involves joint efforts to combat terrorism, address familial issues, preserve the environment, and plan for socioeconomic development. Over time, the interactions between the Centre and the States have played a significant role in shaping the nation's evolution. Strengthened Centre-State relations have led to enhancements in national governance, administrative efficiency, and the integration of diverse communities into the broader societal fabric.

In the intricate web of governance in any federal structure, the relationship between the central government and state governments is paramount. It is the cornerstone upon which the democratic edifice stands, balancing the powers between the central authority and regional autonomy. As we traverse through the dynamic landscape of governance, it becomes evident that the interplay between the center and states is not merely a bureaucratic mechanism but a reflection of the socio - political fabric of the nation.

Over the years, this relationship has evolved, adapting to the changing needs and aspirations of a diverse populace. From the inception of the Indian Republic, the framers of the Constitution envisaged a delicate equilibrium, enshrining principles of federalism while ensuring a strong central authority to maintain unity and integrity.

The journey has been one of negotiation, accommodation, and sometimes contention, as both the center and states assert their respective roles and responsibilities. At the heart of this relationship lies the concept of cooperative federalism, a paradigm that emphasizes collaboration and partnership between the center and states to achieve common goals. This model recognizes that while the central government sets the overarching agenda, states play a crucial role in its implementation, given their nuanced understanding of local issues and realities.

Through mechanisms like the Planning Commission (now NITI Aayog), inter-state councils, and various forums for consultation, efforts have been made to foster synergy and consensus-building among stakeholders. However, the path to harmonious center-state relations is not devoid of challenges. Issues such as fiscal autonomy, administrative jurisdiction, and political differences often surface, testing the resilience of the federal structure. The asymmetry in resources and capacities among states further complicates matters, sometimes leading to disparities in development and governance outcomes.

Striking a balance between autonomy and uniformity, between decentralization and centralization, remains a perpetual conundrum for policymakers. Nevertheless, amidst these challenges, there have been notable strides towards strengthening cooperative federalism. Initiatives like the Goods and Services Tax (GST) and the Finance Commission's recommendations have aimed to enhance financial devolution to states, empowering them to pursue their developmental agendas independently.

Similarly, schemes like the Mahatma Gandhi National Rural Employment Guarantee Act (MGNREGA) and the National Health Mission (NHM) exemplify collaborative efforts where the center provides support while allowing states flexibility in implementation. Moreover, the spirit of federalism is not confined to administrative arrangements but permeates through the socio-cultural ethos of the nation. India's diversity is its strength, and the federal structure celebrates this plurality by accommodating regional aspirations and identities.

End-Notes:

1. Constitution Assembly Debate, Vol 5, P 37, 1949
2. Art 245(2), Constitution of India
3. Suryansh Singh, 'Doctrine of territorial nexus', (Ipleaders, 3 April 2024) accessed on 02/6/24
4. State of Bombay v. RMDC [1957] AIR 699 SCR 874
5. Wallance v. ITC, Bombay [1948] 50 BOMLR 482
6. Art 246(1), Constitution of India
7. Art 246(2), Constitution of India
8. Art 246(3), Constitution of India
9. 'Doctrine of pith and substance', (Ipleaders, 19 March 2022) accessed on 05/6/24
10. Prafful Kumar v. Bank of Commerce [1947] 49 BOMLR 568
11. Doctrine of harmonious construction (Drishti Judiciary, 12 January 2024) accessed on 05/6/24
12. Doctrine of harmonious construction (Byjus, 12 January 2024) accessed on 05/6/24
13. Doctrine of harmonious construction (Byjus, 12 January 2021) accessed on 05/6/24
14. Rameshwar Oraon vs. State of Bihar and Ors. AIR [1995] PAT 173
15. State of Karnataka vs. Union of India [1977] 4 SCC 608
16. State of Rajasthan vs. Union of India [1977] AIR 1361
17. Swaraj Abhiyan vs. Union of India [2018] AIR SUPREME COURT 3670