In April 2025, the Supreme Court's decision in State of Tamil Nadu v. Governor of Tamil Nadu became a landmark moment for Indian federalism. Faced with eight bills that Governor R.N. Ravi had repeatedly withheld or reserved for the President's consideration, the Court declared this inaction "erroneous and illegal" and went so far as to "deem" those bills to have become law on their dates of re-presentation to the Governor. To prevent a repeat, the Court ordered that henceforth the Governor must decide on any ordinary bill within one month, and the President must either assent or return a reserved bill within three months.

Although the Court cited Articles 200 and 201 (which govern how a Governor or President handles state legislation), it actually invoked its broader authority under Articles 142 and 143 to issue these timelines. Critics immediately cried judicial overreach; true to form, President Droupadi Murmu soon used Article 143 to ask the Court whether the Constitution even allows such deadlines. Overnight, what might have been a routine challenge to executive delay became a fulcrum for debates over separation of powers and "complete justice." In this article, we'll trace how Articles 131, 142, and 143 intersected in the Tamil Nadu case, unpacking the Court's reasoning and considering what might come next.

Case Background and Facts (Tamil Nadu vs. Governor)

Between 2020 and 2023, the DMK government in Tamil Nadu passed thirteen reform bills. Each time, the bills went to Governor R.N. Ravi, who in ten instances, either did nothing or immediately "reserved" them for the President's consideration. Even after the Assembly re passed these ten bills without any changes, the Governor refused assent and forwarded them again. Frustrated, the State filed a writ petition under Article 32.

On April 8, 2025, a two judge bench (Justices J.B. Pardiwala and R. Mahadevan) held that Colonel Ravi's inaction violated Article 200's framework and flew in the face of "the very principles of parliamentary democracy." The Court found his motives anything but "bonafide" and concluded that indefinite withholding was impermissible. Exercising its Article 142 power to "do complete justice," the bench directed that all ten bills be treated as having received the Governor's assent on the dates they were last presented. It also laid down that, from now on, a Governor has one month to either assent to or return a bill to the legislature, and if the Governor reserves it, the President then has three months to decide. As a result, those ten DMK bills were "deemed" to be laws as of November 18, 2023 nullifying any further gubernatorial obstruction.

Article 131: Original Jurisdiction and Federal Disputes

Article 131 grants the Supreme Court original jurisdiction over "any dispute…between the Government of India and one or more States" or between multiple States (for example, disputes over water-sharing or boundary lines). Because Article 131 suits are meant to resolve inter governmental clashes, it's rare to see them invoked, especially when a State challenges its own Governor's conduct.

In Tamil Nadu's case, the petition was brought under Article 32 (fundamental rights jurisdiction), not Article 131. The Court quietly agreed that a writ petition was proper. After all, the dispute was not "between the Union and the State" in the classic sense (e.g., over a treaty or contract) but rather a challenge to the Governor's constitutional duty to act on legislation.

Paragraph 434 of the judgment explicitly notes that using Article 32 here was justified. In effect, the Court treated the matter as a constitutional petition, not as an Article 131 suit. Past cases, such as challenges to Governors' withholding of assent in Punjab and Kerala had similarly proceeded as writs rather than original federal suits.

Thus, Article 131 played an indirect role: it established that if Tamil Nadu had truly been embroiled in a dispute with the Union, Article 131 would apply. But since the core issue was "mandamus to compel the Governor to act," Article 32 was sufficient, and Article 131 did not bar this route. When the President later referenced this case under Article 143, some questions even wondered why states would bypass Article 131. Ultimately, the bench endorsed the pragmatic view that controversies over a Governor's inaction can be redressed under Article 32 without a formal federal suit.

Article 142: The Power to Do "Complete Justice"

Article 142(1) empowers the Supreme Court to "pass such decree or make such order as is necessary for doing complete justice in any cause or matter pending before it."  In practice, this residuary power is invoked when ordinary legal remedies prove futile or the law has a gap that only the Court can fill.

In Tamil Nadu v. Governor, all typical remedies had been exhausted: the bills sat in limbo, forcing the legislature to re pass them year after year an outcome that would, in the Court's words, "thwart the will of the people" and undermine democratic governance. Faced with this deadlock, the bench invoked Article 142 to "bridge the gap." And so, rather than remanding the matter or issuing a bland order, the Court said, "we deem the assent to have been granted" on the dates the bills were presented. Only Article 142's broad sweep could "deem" laws into existence, so long as the breach was clear and no other remedy existed.

Unsurprisingly, this sparked fierce debate. Advocates like Indira Jaising argued that, since Governors and Presidents enjoy immunity for official acts, no other legal avenue existed to enforce legislative will. By using its "extraordinary powers," the Court simply prevented "unconstitutional inaction" from nullifying citizens' mandate. The bench insisted it was not rewriting the Constitution but merely ensuring that Article 200's scheme by which a Governor cannot sit on a bill indefinitely continued to operate as intended.

Critics, however, warned that Article 142 was being stretched into a "superpower" wielded routinely against the executive. A DD News analysis complained that by "deeming" bills to have passed, the Court effectively became a legislative body, short circuited normal procedures, and undermined separation of powers. The President's Article 143 reference would soon test whether Article 142 can truly override the Governor's and President's constitutional roles. "Can the Supreme Court's powers under Article 142 override the roles of the President and Governors?" one reference question bluntly asked.

In response, the Court stressed that it had used Article 142 sparingly only after "deepest of deliberations," and only because the Governor's stalling was plainly unconstitutional. The bench also quoted a law commission recommendation that, in deadlock situations, the President should seek advice under Article 143 rather than hold a bill in limbo. In short, the Court defended its exercise of Article 142 as a last resort measure to uphold legislative supremacy when the executive strayed from its constitutional path.

To give future guidance, the judgment then proposed time limits for Article 200 processes: one month for the Governor to act or return a bill, three months for the President to decide on a reserved bill, and another one month limit if the legislature re passes a bill. Although the Constitution nowhere spells out these deadlines, the Court believed they were necessary to prevent "pocket vetoes." In doing so, Article 142 supported both the immediate remedy of "deemed assent" and the prospective rule making authority that binds Governors and Presidents to timelines.

Article 143: Advisory Jurisdiction and the Presidential Reference

Article 143 allows the President to consult the Supreme Court on any question of law or fact "which is of such a nature and of such public importance" that its answer would serve the public interest.  These opinions are advisory they do not bind the executive, but they carry considerable weight.

Interestingly, the Tamil Nadu bench itself urged future use of Article 143. Citing a constitutional review commission, the Court said that if the President doubts a state bill's constitutionality or the Governor's advice, he "ought to make a reference under Article 143" rather than leave bills in limbo. In other words, the Court invited the President to ask for guidance next time instead of blocking legislation indefinitely.

Sure enough, on May 13, 2025, President Murmu invoked Article 143. Her fourteen point reference asked whether the Constitution actually permits a timeline on the Governor or President, or if Article 142 can "override" their discretionary roles. Another question noted conflicting precedents on whether a President's assent (Article 201) is subject to judicial review highlighting deep uncertainty.

The Article 143 reference exposes the tug-of war: the Court used Article 142 to enforce legislative assent, while the President now wants the Court to clarify whether that was constitutional. Since Article 143 opinions are advisory, they won't automatically reverse the Tamil Nadu order. But they will shape legal doctrine going forward. If the Court reaffirms its timeline jurisprudence, States and Governors will face stiffer deadlines. If it scales back, it could reaffirm executive discretion.

Either way, the Article 143 process illustrates a healthy checks and balances moment: the judiciary, executive, and legislature each step back to weigh limits on one another.

Judicial Reasoning, Doctrine, and Likely Outcomes

In Tamil Nadu v. Governor, the Supreme Court's reasoning blended textual interpretation, precedent, and equity.  It insisted that Article 200's first proviso and the Constituent Assembly's vision of the Governor as a "constitutional head" must not be hollowed out by indefinite delays. Quoting historical debates, the bench lamented that a Governor "pouring oil over troubled waters" had instead contributed to gridlock. By invoking Article 142, it cast itself as custodian of "complete justice" when the executive's discretion veered into constitutional defiance.

Legal scholars point out that no direct precedent existed for "deeming assent." A.G. Perarivalan v. Tamil Nadu (2021) had allowed judicial remedy for delayed mercy petitions but that involved clemency, not legislation. In Union of India v. Rajasthan (1977), the Court had refused to override a President's inaction on a state bill, noting that once a bill reached the President, it was final. Tamil Nadu, by contrast, deemed even Presidential steps "void" and forced assent by decree. This suggests a new willingness to subject even "purely executive" acts to judicial scrutiny when legislative deadlock persists.

The coming Article 143 opinion will be critical. If the Court doubles down on its timelines, it may prompt Parliament to amend Articles 200/201 to codify deadlines (something the National Commission to Review the Constitution had already recommended). If the Court qualifies its order emphasising that "deemed assent" was a unique remedy for extraordinary circumstances States may retain more discretion. Either outcome will reshape how Far Right or Opposition ruled governments handle bills passed by rival parties.

For law students, the Tamil Nadu case is a captivating study of how Articles 131, 142, and 143 interact: Article 131 defines original jurisdiction but does not preclude writ remedies; Article 142 offers extraordinary powers to "do complete justice" when all else fails; and Article 143 provides an executive check on judicial overreach. The dance between these provisions executive discretion, judicial remedy, and advisory prerogative reveals much about the Constitution's tension between democratic mandate and constitutional supremacy.

Conclusion
The 2025 Tamil Nadu Governor case showcased the Supreme Court wielding its full constitutional arsenal to resolve a severe legislative executive impasse. By interpreting Articles 200/201 in light of democratic principles, then deploying Article 142 to enforce that interpretation, the Court ensured that the will of the people could not be nullified by bureaucratic delay. Article 131 had only a background role, since the petition used Article 32 rather than a formal federal suit. Article 143 now offers an advisory check on the Court's use of Article 142, decoding whether such assent timelines are truly permissible.


Ultimately, this saga will help define the contours of Indian federalism: How far can Governors and Presidents delay legislation? When will judges step in to "do complete justice?" And how will Article 143 advisory opinions mediate between judicial remedies and executive discretion? For constitutional law students and practitioners alike, the Tamil Nadu case provides a living example of how India's high court navigates separation of powers to uphold legislative efficacy against executive inertia.