The definition of "appropriating funds" makes it sound simple. The appropriation process is not entirely straightforward in practice. Budgeting involves both the legislative and executive departments in a substantial way. The legislature reviews and amends the governor's proposed budget until it is in a form that is acceptable to the legislature, at which point the budget is passed. Executive branch agencies provide budgetary information to the governor, who then develops a proposed budget and submits it to the legislature.

The governor receives the passed budget back for their review. Governors have complete veto power over the passed budget. The majority of states also allow governors to veto specific sections (items) of a measure. In the event of any vetoes by the governor, the budget is sent back to the legislature with the governor's concerns. The legislature has the power to override a governor's veto, making the measure (or parts of it) law in spite of the governor's objections[1].

History
The history of state legislatures' involvement in legislative oversight of appropriation in India is intricate and has changed over time, reflecting the country's transition from colonial authority to a dynamic and democratic nation. British colonial dominance over the subcontinent ended with India's independence in 1947. The British enacted a number of financial laws and rules to govern and regulate India's income and expenses. The Montagu-Chelmsford Reforms, commonly known as the Government of India Act 1919, signified a significant advancement in India's legal and financial framework. With the creation of the Legislative Assembly and the Legislative Council, the idea of "bicameralism" was first established.

India adopted a parliamentary democracy after gaining independence, which was codified in the Constitution of India, which took effect in 1950. Through Articles 202 to 207, the Constitution defined the responsibilities and authority of state legislatures in financial concerns. In several Indian states, state legislatures were founded that were modelled after the Indian Parliament. These legislatures rose to prominence as the main state legislative bodies and were instrumental in establishing budgetary policy.

The founders of India understood the value of budgetary accountability and responsibility. The Constitution established the Comptroller and Auditor General (CAG) to oversee government financial audits and includes rules for the presentation of yearly financial accounts (budgets). The Constitution also established the financial relationships between the federal government and the state governments, guaranteeing the budgetary independence of the states while upholding the union's integrity.

State governments now publish yearly financial accounts to the state legislatures as part of India's evolving budgeting procedures. State legislatures play a key oversight role by outlining revenue projections, projected spending, and appropriations in these statements. To perform in-depth analyses of government spending and financial choices, committees like the Public Accounts Committee (PAC) and the Estimates Committee were set up.

Financial assessment took on a new dimension in jurisdictions where there were legislative councils. The Legislative Council (upper house) may make suggestions without having the authority to veto money legislation, but the Legislative Assembly (lower house) must present all money laws. Financial obligations to Panchayati Raj institutions and urban local councils were further increased by constitutional changes such the 73rd and 74th changes in 1992.

In result, India's historical backdrop of state legislatures' involvement in legislative control on appropriation is a monument to the country's transformation from colonial rule to a strong and transparent democratic fiscal governance system. In order to ensure that state-level financial decisions are consistent with democratic values and advance the welfare of the populace, the Constitution and subsequent legislative changes have established the foundation for financial responsibility.

Provisions
According to Article 202, the state legislature must receive an annual financial report from the state administration. This document, sometimes referred to as the state budget, lists the government's anticipated receipts and outlays for the following fiscal year. The government's financial priorities and intentions are reflected in the budget, which is a key document[2].

According to Article 203, all state accounts, as well as those of its officials and authorities, pertaining to the receipt and disbursement of funds, shall be maintained in the manner specified. This guarantees responsibility and openness in financial concerns[3].

According to Article 204, only through an appropriation law may money be taken from the state's Consolidated Fund. The state legislature must approve the appropriation bill, which details how much money will be taken from the Consolidated Fund and for what reason[4].

When the funds allotted in the yearly budget are inadequate to cover some expenses, Article 205 gives the state legislature the authority to vote extra, additional, or excess grants. These subsidies are given to cover unanticipated or pressing costs that weren't initially planned for in the budget. When the yearly budget has not been approved before the start of the new fiscal year, the state legislature may award a "vote on account" pursuant to Article 206. Until the complete budget is approved, this temporary provision enables the government to take money out of the Consolidated Fund to cover necessary expenses.

When the yearly budget has not been approved before the start of the new fiscal year, the state legislature may award a "vote on account" pursuant to Article 206. Until the complete budget is approved, this temporary provision enables the government to take money out of the Consolidated Fund to cover necessary expenses.

The unique procedure for money measures in the state legislature is outlined in Article 207. The Legislative Assembly (Vidhan Sabha) must be the first-place money bills are introduced if they are the only ones that deal with issues linked to taxes, spending, or the Consolidated Fund. If there is a Council (Legislative Council or Vidhan Parishad) in the state, it can only suggest money legislation; it cannot prevent them from being passed.
A money bill is forwarded to the Governor for approval after being approved by the Legislative Assembly, according to Article 208. The Governor's assent is often a formality, and once the Governor signs off on a measure, it becomes a law.

Each state legislature is free to enact its own regulations under Article 209 regarding the presentation and passage of budgets, appropriation bills, and money bills, as well as other financial concerns. These guidelines are often provided in the different state legislatures' Rules of Procedure.[5]

Case Laws:

• State of West Bengal v. The Bank of India, (AIR 1959 SC 1359)[6]: The Supreme Court of India headed that any amendments to an appropriation bill that would have the effect of altering the amount or altering the destination of any grant thus made or that would have the effect of altering the amount of any expenditure charged to the Consolidated Fund of the State are forbidden by Article 204 of the Indian Constitution. The conflict happened when a West Bengal Appropriation Bill, 1959 alteration that sought to reduce the amount of a grant previously provided to the Bank of India was challenged. In accordance with the Supreme Court, the amendment was unlawful under Article 204 since it would alter the size of a grant that had already been made. The Supreme Court also ruled that the Legislature could not alter Article 204 since it is an essential principle of the Constitution. This is to ensure that Article 204 may ensure that the Legislature will not interfere with the Executive's financial independence. A key case in the analysis of Article 204 of the Constitution is the ruling in State of West Bengal v. The Bank of India. It helped establish the idea that Article 204 is an essential component of the Constitution and has been utilized a great deal in later judgments.
   
• State of Rajasthan v. Union of India [7]: In accordance with the Supreme Court of India, every bill for money except from appropriation bills are exempted from the regulations of Article 204 of the Indian Constitution. The Rajasthan Appropriation Bill, 1977, which included provisions for the imposition of new taxes, was objected to, giving rise to the case. The Supreme Court decided that Article 204 did not apply since the Bill qualifies as a Money Bill under Article 110 of the Constitution. The Supreme Court also held that the Legislature is free to pass taxes however it sees fit because the collection of taxes is a matter of policy. The Court additionally ruled that judicial review is not accessible for the Legislature's ability to impose taxes.
   
• S.R. Bommai v. Union of India [8]: Because it affirmed the essential nature of Article 204 and its function in preserving the Executive's financial autonomy, the judgment in this case is noteworthy in the context of Article 204 of the Indian Constitution. In accordance with the Supreme Court, the Legislature cannot alter Article 204 as it is an essential principle of the Constitution. The Court held that Article 204 must exist to ensure that the Legislature does not impact the Executive's financial independence. The Court also ruled that Article 204 is inferred by the Constitution's overall design. The Constitution established an arrangement of division of power between the legislature, the executive branch, and the judiciary, the court stated. Every branch of government has its own level of autonomy, and none of the branches can interfere with the power of the other branches. The Court concluded that Article 204 is crucial for preserving the Executive's financial independence. The Executive is in the position of administering the State and enforcing the laws that have been approved by the Legislature. To effectively carry out his responsibilities, the Executive needs financial independence.
   
• Sri Ramulu v. State of Andhra Pradesh, [9]: In accordance with the Andhra Pradesh High Court, Article 204 of the Indian Constitution forbids the insertion of new items of expenditure to an appropriation bill. The conflict began from a challenge to an inclusion of a new item of expenditure for the construction of a new bridge to the Andhra Pradesh Appropriation Bill, 1963. The High Court decided that the amendment was invalid under Article 204 as it would alter the size or intended recipient of any grant provided in that way. In accordance with the High Court, Article 204 prohibits the Legislature from making any modifications to an appropriation bill that would have the effect of altering the amount or destination of any grant made within that clause. The Court determined that this restriction is required to make sure that the Legislature does not impact the Executive's financial independence. As it sustains the ban on amending appropriation bills to include new items of spending, the Sri Ramulu ruling is relevant in the context of Article 204. This restriction is necessary to safeguard the Executive's financial independence.
   
• State of Kerala v. C.E. John[10]: It is a further significant case law on Article 205 of the Indian Constitution. The Supreme Court decided in this case that the government cannot make a purchase in anticipation of getting additional money from the legislature. If the executive makes this choice, it will be deemed an unauthorized expenditure. The procurement of new buses for the state transportation company cost the Keralan government 25 crore Indian rupees. The legislature had not provided a further grant with the government to reimburse it for this expense. The government responded that it had made the decision to buy in anticipation of receiving extra funding from the legislature. The Supreme Court ruled that the expenditure was unconstitutional and rejected the government's argument. The Supreme Court decided that the executive cannot plan a bill based on the expectation of a future grant from the legislature. The Court further decided that even if the government is confident that the legislature will offer a supplemental grant for the expense, it remains unlawful of it to spend the expense. The State of Kerala v. C.E. John (2003) decision is an essential obstacle against the executive using public funds without authorization. It makes sure that the executive must answer to the legislative for its spending and that it is forbidden from accomplishing so without permission.
   
• State of Tamil Nadu v. Thiru R. Muthu Kumar[11]:
  The Supreme Court of India issued an important decision in the 2016 case of State of Tamil Nadu v. Thiru R. Muthu Kumar that clarifies the use of Article 205 of the Constitution. Article 205 states that "no money shall be withdrawn from the Consolidated Fund of India except under appropriation made by law by Parliament." In this case, the government of Tamil Nadu spent 100 crores on building a new stadium. The legislature hadn't given a further grant for the government to pay for this cost. The Tamil Nadu government's expenditure was determined to be illegal and subject to repayment by the Supreme Court. The Court also held that Article 205 is a mandatory provision and that government agencies cannot bypass it by using other Constitution provisions, such as Article 283, for doing so.
   
• State of U.P. v. Raj Narain (1975)[12]": Because it upheld the requirement that the provision be followed, the case of State of U.P. v. Raj Narain (1975) is significant in the context of Article 205 of the Indian Constitution. On the grounds of voter fraud, the Allahabad High Court ruled Indira Gandhi's election as the then-prime minister of India to the Lok Sabha invalid. She had been refused the right to stand for office by the High Court for a duration of six years. In the Supreme Court, the Uttar Pradesh government referred to the High Court's ruling. On the grounds of fraud in elections, the Supreme Court upheld the High Court's ruling, but it affirmed the disqualification order.
  
  Even though Gandhi was no longer a member of the House, the Supreme Court headed that the Governor was still obligated to provide the State Legislature with a statement of the estimated amount of expenses incurred by the government related to her election. Because it identified that the Governor's power to hand over the statement of expenditure to the State Legislature is a mandatory power and cannot be refused, the decision of the Supreme Court in this case was important. This makes sure that the Legislature will hold the State Government financially accountable. Additionally, it is significant because it led to the statement of a state of emergency in India in 1975. Gandhi stated a state of emergency to stop the Legislature from excluding her from running for office. Gandhi limited civil liberties and suspended fundamental rights during the two-year state of emergency.

Need And Significance
In India's democratic system, the function of state legislatures in legislative control over allocation symbolizes a crucial necessity and is of utmost importance. At its heart, this function is the embodiment of democratic values, guaranteeing that elected officials, who are directly answerable to the people, have the power to supervise and have an impact on how public monies are distributed and used. The foundation of responsible governance is this democratic accountability, which creates a vital link between the government's spending decisions and the will of the population.

Furthermore, the establishment of a system of checks and balances within the government depends on parliamentary control over appropriation. It serves as a buffer against possible abuses of power and the misappropriation of public resources by fostering an atmosphere of openness and accountability in which the executive is answerable to the legislative and, consequently, to the general public. This approach not only upholds democratic principles but also guards against arbitrary financial judgements that can go against the larger interests of the people.

Also, openness is a key component of parliamentary appropriation control. The ability to acquire thorough information regarding government expenditures, budgetary allotments, and resource distribution across various sectors is granted to the populace. Citizens are better able to assess whether government activities are in line with its stated aims and policies thanks to this openness, which gives them the information they need to make educated decisions. This encourages confidence and responsibility by making the financial process a joint effort between the government and the governed.

Another important aspect of legislative control is prudent financial management. The legislature guarantees that the government maintains economic restraint by approving budgets and appropriations. This control is crucial to preventing careless spending, the buildup of unmanageable debt, or the adoption of risky fiscal practices that might endanger the state's capacity to maintain its economic stability[13].

Parliamentary oversight of appropriations synchronizes budgetary choices with the state's developmental objectives and demands. It ensures that funds are distributed effectively and openly to industries and initiatives that deal with urgent problems including healthcare, education, infrastructure development, poverty reduction, and more. By ensuring that public expenditures are allocated where they are most needed, this alignment improves the general welfare of the populace.

In result, the importance and necessity of legislative control over appropriations in state legislatures in India capture the very spirit of democratic government, responsibility, openness, and financial responsibility. It stands for a crucial mechanism that upholds democratic values, protects the interests of the populace, and advances the nation's and its people's economic well-being[14].

Working In Unicameral And Bicameral

Working in unicameral
Working in a Unicameral State Legislature entails a variety of crucial tasks carried out by different people and experts who contribute to the state's budgetary governance. These positions cover a wider range of specialists, authorities, and staff employees in addition to lawmakers.

Experts in finance, economics, and policy analysis constitute the system's backbone, and they are crucial to developing and evaluating budget recommendations. They offer in-depth insights into intricate financial issues, assisting in making sure that the budget is in line with the state's economic goals and long-term financial stability.

The legislative body's financial experts and budget analysts are in charge of thoroughly examining budget recommendations. Their thorough review guarantees the accuracy and fiscal responsibility of revenue projections, projected spending, and appropriations.

The legal framework controlling appropriations is interpreted and navigated with the help of legal specialists and consultants. They support maintaining the integrity of the legislative process by assisting in ensuring that financial choices are made in accordance with applicable rules and regulations.

The mechanics of the budgetary procedure are made easier by the administrative and support employees. They support the smooth operation of the legislative process by helping to plan committee meetings, hearings, and record-keeping.

Additionally, engaging the public and stakeholders requires the assistance of communication experts and public relations staff. They aid in the communication of budgetary information, the gathering of comments, and the promotion of legislative process openness.

Accountants and auditors supervise the financial facets of budget execution and carry out post-budget audits to monitor money usage. Their work promotes accountability and guarantees the proper use of public finances.
In result, a broad and cooperative effort by experts from numerous sectors is required to function within a Unicameral State Legislature in the legislative control on appropriation. Collectively, these people help to shape the state's fiscal policies, assuring openness, responsibility, and prudent financial management for the benefit of the state and its residents[15].
Working in bicameral

Working within a bicameral State Legislature requires a complex framework that goes beyond the responsibilities of lawmakers in the context of legislative power over appropriation. It includes a variety of specialists, professionals, and representatives who support the state's fiscal governance and the examination of financial issues.

In-depth analyses of the state's economic environment are largely provided by financial specialists and economists. In order to create solid fiscal policies and make sure that budgetary decisions are in line with the state's economic aims, they analyse budget plans, revenue projections, and economic predictions.

The legislative body's legal consultants and specialists are crucial in understanding the intricate legal system controlling appropriations. They protect the legitimacy and integrity of the budget process by ensuring that budgetary choices are made in compliance with all applicable rules and regulations.

Support personnel are necessary to plan meetings, hearings, and documents for legislative committees that deal with fiscal issues. These experts aid in planning and conducting a thorough assessment of budget ideas, which helps to ensure a complete review.

In order to manage the logistical parts of the budgetary process, administrative staff personnel are essential. They support the smooth operation of the legislative machinery by helping to schedule legislative sessions, coordinate communications between chambers, and keep records.

It's crucial to communicate with the general public and stakeholders effectively. Public relations and communication professionals collaborate to engage people, convey budget information, and receive feedback. They are essential in promoting openness and public awareness.

Accounting and auditing experts are in charge of managing the budget's financial components. They carry out post-budget audits to keep track of how money is being used, ensuring that monies are allocated as planned and enforcing accountability.

Legislative committee researchers undertake in-depth studies of budget proposals and offer data-driven insights. Their work enables lawmakers and committee members to make well-informed appropriations choices.
Officials from the executive branch work with legislative bodies to offer budget ideas, including finance ministers and budget directors. They interact with lawmakers during budget hearings and give thorough arguments and justifications for budgetary allocations.

External parties involved in the financial process, such as advocacy groups and civil society organisations, frequently offer important influence. They interact with lawmakers, arguing for particular causes and making sure that budget choices take the community's larger interests into account.

In summary, operating within a bicameral State Legislature requires a collaborative effort encompassing a wide range of experts and stakeholders. Collectively, these people support the state's financial management, ensuring that the budget is carefully examined, complies with economic and legal frameworks, and serves the interests of the state and its citizens[16].

Comparision With International Perspective

Internationally, the separation of powers is embraced by many democracies, including India. Similar to parliaments in other countries, state legislatures serve as an important check on the financial power of the executive branch. To maintain financial responsibility, they examine, modify, and approve budgets.

Everywhere in the globe, legislative control over appropriations serves the same fundamental purpose. Legislators examine proposed budgets from the executive branch to make sure they represent public goals and uphold sound financial management. This function of supervision is crucial for preserving the balance of power.

Similar to India's Public Accounts Committee (PAC) and the Estimates Committee, several other nations have committee structures in place for thorough budget review. These committees review spending, investigate the specifics of the budget, and suggest modifications.

Budgetary bill debates are a common occurrence. To guarantee that financial allocations are in line with the requirements and interests of the country, legislators from different nations have debates.
From a global viewpoint, audits carried out by independent organizations like to India's Comptroller and Auditor General (CAG) are crucial accountability tools. These controls assist to uphold openness and stop improper use of public monies.

A number of nations, including India, have two houses of parliament, the Legislative Assembly and the Legislative Council. When it is present, the upper house adds another level of scrutiny to the budget review process.
To increase efficiency and openness, nations frequently compare their legislative budgeting procedures to global best practices. They could make modifications to bring their procedures into line with international norms. It is being widely understood how important it is for the public, advocacy organizations, and civil society to be involved in financial debates. Public dialogues and activities for participatory budgeting are expanding internationally.

But it's important to recognize that every country is different. The constitutional structure and political traditions of any nation can have a considerable impact on the precise responsibilities, processes, and authority that legislators have when it comes to managing appropriations. Some nations could have fiscal systems that are more centralized, while others might give significant financial power to sub-national organizations.

Comparison With International Countries

• The United States of America The Congress, the bipartisan legislature, has a lot of power over appropriations in the United States. The "power of the purse," which the Constitution affords Congress, enables it to authorise, modify, and distribute government monies. To evaluate and approve federal expenditures, Congress maintains committees like the House Appropriations Committee and the Senate Committee on Appropriations. A budget proposal from the president is permitted, but legislative approval is required. Because the United States is governed by a federal government, each state has independent legislative authority over its state budget.
  
  
• United Kingdom The UK Parliament, which consists of the elected House of Commons and the appointed House of Lords, has legislative authority over appropriation. The budget is presented to the House of Commons by the Chancellor of the Exchequer, and it is up for discussion and approval in parliament. The Treasury Committee and the Public Accounts Committee are essential to financial supervision. In the United Kingdom, the majority of financial decisions are made by the central government under a unitary system.
  
  
• Germany The federal government and the states (Länder) each have different fiscal duties under Germany's federal system. The federal budget must receive approval from the Bundestag (federal parliament). Although state legislatures are in charge of their own budgets, they also get funding from the federal government. The Bundestag's Budget Committee is in charge of managing finances.
  
  
• Australia Australian government is federal, and state and federal governments each have their own budgets. The House of Representatives and the Senate make up the Parliament, which is where the federal budget is presented. The Joint Committee of Public Accounts and Audit is in charge of overseeing government finances. Although states have their own legislatures and budgets, they may still receive federal funding.
  
  
• South Africa With the National Assembly and the National Council of Provinces (NCOP), South Africa has a bicameral parliament. National budget is presented by the minister of finance to the National Assembly for discussion and approval. The National Assembly's financial affairs are under the control of the Standing Committee on Finance. South Africa has a unitary government but has delegated authority to the provinces, each of which has its own legislature and is in charge of some areas of the budget.

Conclusion
The state legislatures in India are vital for the process for appropriation. They are in the position of approving the state budget, which explains how the administration plans to spend funds. The legislatures also have the power to supervise the implementation of budgets and hold the executive branch responsible for its spending choices.

India's appropriation process is complex and involves an extensive number of players. State legislatures are crucial to this process, but they are additionally under the sway of other entities like the national government, the bureaucracy, and other interest groups.

The state legislatures of India are essential to the appropriation process, when summed up. The state budget, containing all appropriations for state government programs and services, must be examined and endorsed by them. In addition, state legislatures have the authority to look at government spending and hold it accountable.

The state legislature's appropriation process typically involves three steps:
The government suggests the budget to the legislature, the legislature debates the budget and changes it as necessary, and at last, the legislature adopts the budget, and it becomes law. The state legislatures can carry out their appropriation duty using an array of tools and procedures, including standing committees, performance audits, and public hearings. The state legislatures have an important effect on whether the state budget is just and equitable as well as if it satisfies the needs of the people

End Notes:

1. https://www.ncsl.org/about-state-legislatures/separations-of-powers-appropriation-powers
2. https://www.lawglobalhub.com/article-202-207-indian-constitution-1949/
3. https://www.lawglobalhub.com/article-202-207-indian-constitution-1949/
4. https://www.lawglobalhub.com/article-202-207-indian-constitution-1949/
5. https://www.lawglobalhub.com/article-202-207-indian-constitution-1949/
6. State of West Bengal v. The Bank of India, AIR 1959 SC 1359
7. State of Rajasthan v. Union of India, AIR 1977 SC 1361 (INDIA)
8. S.R. Bommai v. Union of India, AIR 1994 SC 1918 (INDIA)
9. Sri Ramulu v. State of Andhra Pradesh, AIR 1964 AP 133 (INDIA)
10. State of Kerala v. C.E. John AIR 2003 SC 1338 (INDIA)
11. State of Tamil Nadu v. Thiru R. Muthu Kumar 2016 SCC OnLine Mad 2443 (INDIA)
12. State of U.P. v. Raj Narain 1975 SCC (4) 428 (INDIA)
13. https://www.oecd.org/gov/budgeting/43411793.pdf
14. https://www.oecd.org/gov/budgeting/43411793.pdf
15. https://egyankosh.ac.in/bitstream/123456789/63030/1/Block-6.pdf
16. https://egyankosh.ac.in/bitstream/123456789/63030/1/Block-6.pdf
17. https://constitution.congress.gov/browse/essay/artI-S9-C7-1/ALDE_00001095/
18. https://www.parliament.uk/globalassets/documents/commons-information-office/p06.pdf
19. https://www.oecd.org/gov/budgeting/Budget-Review-Germany.pdf
20. https://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Library/pubs/rp/rp1819/Quick_Guides/AppropriationsPowersSenate
21. https://www.treasury.gov.za/legislation/bills/2023/[B3-2023]%20(Appropriation).pdf